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BLM    LIBRARY 


8801: 


U.S.  DEPARTMENT  OF  THE  INTERIOR 

Bureau  of  Land  Management 


Final 


Oregon  State  Office 


May  1983 


Roseburg 

Timber  Management 
Environmental 
Impact  Statement 


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IN  REPLY 
REFER  TO: 


United  States  Department  of  the  Interior 


BUREAU  OF  LAND  MANAGEMENT 

Roseburg  District  Office 
777  N.W.  Garden  Valley  Blvd. 
Roseburg,  Oregon  97470 


1792 


May  27,  1983 


This  is  the  final   environmental    impact  statement  (FEIS)  on  the  10-year  timber 
management  plan  for  the  Douglas  and  South  Umpqua  Sustained  Yield  Units  in  the 
Roseburg  District.     The  purpose  of  the  statement  is  to  disclose  the  probable 
environmental   impacts  and  to  assure  that  these  impacts  are  considered  along 
with  economic,  technical   and  other  factors   in  the  decisionmaking  process.      In 
using  this  analysis,  readers  should  keep  in  mind  that  a  FEIS  is  not  the 
decision  document.     A  final  decision  will  ccme  later  and  will  be  announced   in 
a  Record  of  Decision. 

A  major  issue  of  BIM's  timber  management  throughout  western  Oregon  has  been 
concern  regarding  which  uses  of  the  forest  land  base  were  authorized  under 
the  terms  of  the  O&C  Act  and  subsequent  legislation.     In  March  1983, 
following   a  major  legal   review  and  analysis  of  these  authorities,  BLM 
Director  Robert  Burford  issued  a  new  O&C  Forest  Resources  Policy  defining  the 
agency  position  for  the  management  of  forest  lands  in  western  Oregon.     The 
proposal  developed  from  application  of  the  policy  (see  Appendix  A)   is 
identified  in  the  statement  as  the  New  Preferred  Alternative   (Alternative  9). 

This  EIS  is  being  released  in  accordance  with  a  schedule  contained  in  the 
agreement  of  February  19,   1976,  relative  to  the  litigation  in  the  U.S. 
District  Court  for  the  District  of  Columbia,  entitled  Natural  Resource 
Defense  Council,  Inc.,  et  al .  v.  Thomas  S.  Kleppe,  et  al.,  Civil  No.  75-1861. 
Due  to  the  addition  of  a  New  Preferred  Alternative  (Alternative  9),   a  60-day 
comment  period  on  the  FEIS  is  established.     Comments  received  by  the  Roseburg 
District  before  August  1,  1983  will  be  considered  prior  to  the  release  of  a 
Roseburg  Record  of  Decision. 

Sincerely  yours, 

l>    James  E.  Hart 
District  Manager 


Bureau  of  Land  Management 

Library 

Bldg.  50.  r~  ral  Center 

Oenver,  CO  80225 


0123-^ 


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U.S.  DEPARTMENT  OF  THE  INTERIOR 

Bureau  of  Land  Management  ^  ~J 

BUi  Library  ~  §>  g 

D-653A,  Buildirg50 
Denve     fi  ec  -    al  canter 
P.O.  Bcxi,6o47 
Denver,  CO  80225-0047 


FINAL 


ENVIRONMENTAL 
IMPACT   STATEMENT 


Roseburg 
Sustained  Yield  Units 

Ten-Year 

Timber  Management  Plan 

eauofU. 
UbjW  Center 

Denver,  CO  80225  ^ 


Prepared  By 

U.S.  DEPARTMENT  OF  THE  INTERIOR 

BUREAU  OF  LAND  MANAGEMENT 

1983 


State  Director,  Oregon  State  Office 


Roseburg  Proposed  Timber  Management 


VICINITY     MAP 


ROSEBURG     SYUS 


Draft  ( )  Final  (x)  Environmental  Impact  Statement 
Department  of  the  Interior,  Bureau  of  Land  Management 

1.  Type  of  Action:  Administrative  (x)  Legislative  (  ) 

2.  Abstract:  This  EIS  describes  and  analyzes  the  environmental  impacts  of  implementing  an  updated  10-year 
(1984-1993)  timber  management  plan  for  the  423,896  acres  of  public  land  in  the  Douglas  and  South  Umpqua 
Sustained  Yield  Units  in  the  Roseburg  District,  Oregon.  The  Bureau  of  Land  Management  is  responsible  for 
managing  timber  on  public  lands  under  the  principle  of  sustained  yield.  Nine  alternatives  are  described  and 
analyzed  for  environmental  impacts.  The  alternatives  analyzed  include:  1)  Maximum  Timber  Production,  2) 
Strong  Emphasis  on  Timber  Production,  3)  Lower  Average  Minimum  Harvest  Size,  4)  the  Original  Proposed 
Action,  5)  No  Action,  6)  Habitat  Diversity,  7)  No  Herbicides,  Fertilizer  or  Allowable  Cut  Effect  for  Genetics, 
8)  Emphasis  on  Protection  of  Natural  Values,  9)  New  Preferred  Alternative.  Specific  timber  management 
components  of  the  alternatives  include  road  construction,  timber  harvest,  site  preparation,  reforestation, 
plantation  protection,  precommercial  thinning,  fertilization  and  control  of  competing  vegetation. 
Significant  environmental  impacts  of  the  New  Preferred  Alternative  include  wildlife  habitat  modification; 
soil  erosion,  landsliding  and  stream  sedimentation;  and  increased  timber  harvest  and  employment. 

3.  Due  to  the  addition  of  a  New  Preferred  Alternative,  a  60-day  comment  period  on  the  FEIS  is  established. 
Comments  will  be  accepted  by  the  Roseburg  District  Manager  until  August  1,  1983,  at  the  address  listed 
below. 

4.  For  further  information  contact: 

Bob  Alverts,  Planning  Coordinator 
Bureau  of  Land  Management 
Roseburg  District  Office 
777  NW  Garden  Valley  Blvd. 
Roseburg,  Oregon  97470 
Telephone  (503)  672-4491 


Summary 


Introduction 

This  environmental  impact  statement  (EIS) 
describes  and  analyzes  the  environmental  impacts 
of  implementing  an  updated  10-year  (1984-1993) 
timber  management  plan  for  the  Douglas  and 
South  Umpqua  Sustained  Yield  Units  in  the 
Roseburg  District,  Oregon.  Hereafter,  the 
Sustained  Yield  Units  will  be  referred  to  as  the 
Roseburg  Sustained  Yield  Units  or  simply  the 
SYUs.  This  EIS  applies  to  actions  proposed  for  the 
423,896  BLM-administered  acres  within  the 
combined  SYUs.  These  are  primarily  revested 
Oregon  and  California  Railroad  (O&C)  lands  and 
reconveyed  Coos  Bay  Wagon  Road  (CBWR)  lands. 
There  are  also  scattered  remnants  of  the  original 
Public  Domain  (PD)  lands. 

Approximately  402,000  acres  of  the  land  area  in 
the  Roseburg  SYUs  is  commercial  forest  land,  with 
an  additional  21,900  acres  in  non-commercial 
forest  or  non-forest  categories.  To  the  extent 
possible,  non-forest,  non-intensive  commercial 
forest  land  and  withdrawn  areas  have  been  used  to 
partially  provide  a  variety  of  forest  resource  uses, 
including  habitat  for  threatened  and  endangered 
species  and  other  wildlife,  as  well  as  watershed, 
recreation,  scenic  and  other  values. 

In  accordance  with  the  National  Environmental 
Policy  Act,  this  EIS  identifies  impacts  on  the 
natural  and  human  environment  associated  with 
nine  alternatives.  The  EIS  is  based  primarily  on 
data  collected  and  analyzed  through  the  Bureau 
planning  system  which  included  extensive  public 
involvement.  Alternative  9,  developed  to  meet  new 
policy  for  O&C  lands,  is  the  Preferred  Alternative. 
Eight  other  alternatives  have  been  identified, 
providing  a  wide  range  of  options  for  review  and 
consideration.  A  basic  assumption  incorporated 
into  the  analysis  is  that  sufficient  funding  and 
personnel  will  be  available  for  implementation  of 
any  alternative. 


Alternatives 

Timber  harvest  under  all  alternatives  would 
be  accomplished  predominately  by  clearcutting, 
with  some  single  tree  selection.  Intensive  timber 
management  treatments  would  include 
construction  of  logging  roads,  site  preparation 
with  burning,  mechanical  means  and  herbicide 
application,  planting  coniferous  trees  (including 
genetically  improved  stock),  plantation  protection, 
plantation  maintenance  and  release  with 
herbicides  or  manual  means,  precommercial 
thinning  and  fertilization.  Alternative  7  excludes 
the  use  of  herbicides  and  fertilization. 

Variables  among  alternatives  include  amounts  of 
land  allocated  to  timber  production,  types  and 
amounts  of  intensive  management  practices, 
harvest  scheduling  and  constraints  on  timber 
harvest  to  benefit  other  resource  values.  The 
minimum  size  of  timber  available  for  final  harvest 
also  varies  by  alternative.  Harvest  at  the  minimum 
size,  reached  in  40  to  50  years  for  all  alternatives 
except  8,  would  begin  in  approximately  the  fifth 
decade.  Harvest  at  the  minimum  size  would 
continue  for  6  to  23  decades,  depending  on  the 
alternative.  The  proposed  alternatives  are: 

1.  Maximum  Timber  Production.  This  alternative 
maximizes  timber  production  while  meeting  legal 
requirements  to  protect  federally  listed  threatened 
and  endangered  species  and  cultural  resources.  It 
would  allocate  386,622  acres  of  commercial  forest 
land  to  intensive  timber  management  and  produce 
an  annual  timber  sale  program  of  289  MM  bd.  ft. 
Operational  and  spatial  constraints  on  timber 
harvest  and  stand  regeneration  would  be 
minimized.  The  average  minimum  size  of  trees  in 
stands  available  for  final  harvest  would  be  12.7 
inches  diameter  breast  height  (dbh),  normally 
reached  in  40  years. 


2.  Emphasis  on  Timber  Production.  This 
alternative  would  allocate  360,580  acres  of 
commercial  forest  land  to  intensive  timber 
management  with  an  additional  24,786  acres 
managed  under  modified  area  control.  This  would 
produce  an  average  timber  sale  program  of  267 
MM  bd.  ft.  annually.  A  longer  harvest  cycle 
(average  of  250  years)  under  modified  area  control 
would  provide  timber  harvest  while  protecting 
some  resources  in  riparian  areas,  wildlife  habitat 
and  visual  corridors.  The  average  minimum 
diameter  of  trees  in  stands  available  for  final 
harvest  would  be  14.4  inches  dbh,  normally 
reached  in  50  years. 

3.  Lower  Average  Minimum  Harvest  Size.  This 
alternative  allocates  333,319  acres  of  commercial 
forest  land  to  intensive  timber  management  with 
an  additional  52,047  acres  managed  under 
modified  area  control.  Under  the  intensive  timber 
production  base,  the  average  minimum  diameter  of 
trees  in  stands  proposed  for  final  harvest  would  be 
12.7  inches  dbh,  normally  reached  in  40  years. 
This  alternative  would  produce  an  average  timber 
sale  program  of  256  MM  bd.  ft.  annually. 

4.  Original  Proposed  Action.  This  alternative  is 
identical  to  Alternative  3  except  that  minimum 
harvest  size  is  increased,  shortening  the  time  to 
achieve  a  regulated  forest.  The  minimum  average 
tree  diameter  in  stands  selected  for  final  harvest 
would  be  14.4  inches  dbh  compared  to  12.7  inches 
dbh  under  Alternative  3.  The  minimum  harvest  age 
would  be  50  years,  providing  an  average  annual 
timber  sale  program  of  249  MM  bd.  ft. 

5.  No  Action  (No  Change).  A  required  alternative 
in  the  EIS,  this  would  constitute  a  continuation  of 
the  present  annual  timber  sale  program  of  201  MM 
bd.  ft.  on  390,984  acres.  It  would  continue  the 
intensive  management  practices  and  constraints 
identified  in  the  1972  allowable  cut  determination. 
Non-timber  allocations,  limited  to  400  acres, 
include  buffers  for  recreation  areas  and  sensitive 
visual  corridors.  Streamside  buffers  totaling  8,070 
acres  would  be  provided  along  third  order  and 
larger  streams. 

6.  Habitat  Diversity.  This  alternative  emphasizes 
protection  of  natural  and  cultural  values,  while 
accommodating  production  of  timber.  It  would 
allocate  222,357  acres  to  intensive  forest 
management  with  an  additional  119,924  acres 
managed  under  longer  harvest  cycles.  The  annual 
timber  sale  program  would  be  183  MM  bd.  ft.  The 
minimum  average  diameter  of  trees  in  the  intensive 
timber  management  stands  available  for  final 
harvest  would  be  14.4  inches  dbh,  normally 
reached  in  50  years. 

7.  No  Herbicides,  Fertilizer  or  Allowable  Cut  Effect 
for  Genetics.  This  alternative  is  similar  to 
Alternative  4  in  timber  base  and  treatments,  except 
that  herbicides  and  fertilizer  would  not  be  used.  It 
would  provide  for  continued  planting  of 


genetically  improved  trees,  but  the  allowable  cut 
computation  would  not  take  credit  for  expected 
growth  increases.  The  average  timber  sale 
program  would  be  176  MM  bd.  ft.  annually.  The 
minimum  average  diameter  of  trees  in  stands 
available  for  final  harvest  would  be  13.6  inches 
dbh,  normally  reached  in  50  years.  Vegetation 
management  practices  in  lieu  of  herbicides  would 
be  prescribed  to  approximately  the  same  dollar 
level  of  investment  as  would  be  used  for  fertilizer 
and  herbicide  applications. 

8.  Emphasis  on  Protection  of  Natural  Values. 

Under  this  alternative,  protection  is  provided  for  a 
variety  of  wildlife  habitats,  sensitive  botanical 
species,  cultural  resources,  visual  resources, 
research  natural  areas,  riparian  areas  and 
dispersed  recreational  activities.  Approximately 
262,436  acres  of  commercial  forest  land  would  be 
included  in  the  constrained  timber  base.  Minimum 
harvest  ages  would  vary  from  60  to  350  years.  This 
would  produce  an  annual  timber  sale  program  of 
84  MM  bd.  ft.  Fifteen-year  spacing  between  harvest 
areas  would  be  employed.  Timber  harvest  would 
be  allowed  only  when  direct  benefit  to  the 
protected  resources  would  result.  This  is 
considered  to  be  a  full  ecosystem  alternative. 

9.  New  Preferred  Alternative.  This  alternative  is  a 
modification  of  the  Original  Proposed  Action 
(Alternative  4)  resulting  from  application  of  the 
new  O&C  Forest  Resources  Policy.  The  alternative 
seeks  a  high  level  of  timber  production  (247  MM 
bd.  ft. /year)  while  managing  for  a  variety  of  natural 
values  and  recreation  opportunities.  This 
alternative  would  allocate  331,637  acres  of 
commercial  forest  land  to  intensive  management 
with  an  additional  35,868  acres  managed  under 
modified  area  control.  An  estimated  23,565  acres 
of  commercial  forest  land  would  be  withdrawn  to 
protect  riparian  areas,  bald  eagles,  Research 
Natural  Areas,  botanical  species  and  cultural 
resources. 


Environmental 
Consequences 
Air  Quality 


The  major  impact  on  air  quality  would  be 
from  slash  burning.  Particulate  emissions  range 
from  1,142  tons  to  3,828  tons  per  year. 

Soils 

Impacts  to  soils  are  mainly  due  to  road 
construction,  landslides  and  compaction. 
Alternative  1  has  the  greatest  long-and  short-term 
impacts  while  Alternative  8  has  the  least. 
Production  losses  range  from  2,647  equivalent 
acres  under  Alternative  8  to  9,136  equivalent  acres 
under  Alternative  1.  Less  significant  impacts 
include  nutrient  losses,  dry  ravelling  and  topsoil 
removal. 


Water  Resources 

Sediment  yield  would  increase  under 
Alternatives  1  to  3,  decrease  under  Alternatives  4, 
6,  7,  8  and  9.  Water  yield  increases  are  expected 
under  Alternatives  1  to  5  and  9,  decreases  under 
Alternatives  6,  7  and  8.  Water  temperature  would 
increase  under  Alternative  1.  Based  on  the  sample 
5-year  sale  plan,  timber  harvest  activities  planned 
in  four  municipal  watersheds  would  increase  water 
yield  and  sedimentation. 


Vegetation 


Alterations  to  plant  community  structure  and 
longevity  would  be  the  most  significant  impacts  to 
vegetation  on  lands  scheduled  for  timber  harvest. 
Acres  scheduled  for  timber  harvest  over  the  next 
decade  would  range  from  74,807  under  Alternative 
1  to  19,915  under  Alternative  8.  Mature  and  old- 
growth  forest  communities  would  be  converted  to 
early  successional  stage  communities  as  slow- 
growing  timber  stands  are  replaced  by  young,  fast- 
growing  stands.  Diversity  and  complexity  of  plant 
communities  would  diminish  as  maximum  growth 
of  commercial  conifers  is  emphasized.  Changes  in 
plant  communities  and  habitat  could  eliminate 
some  plant  species  in  the  long  term.  Plant  habitat 
altered  by  herbicides  would  increase  under  all 
alternatives  except  7  and  8.  Permanent  road 
construction  during  the  decade  would  eliminate 
vegetation  from  public  land,  ranging  from  5,568 
acres  under  Alternative  1  to  1,662  acres  under 
Alternative  8. 

Animals 

Habitat  diversity  would  increase  in  the 
short  term.  However,  in  all  alternatives  except  8, 
there  would  be  significant  long-term  adverse 
impacts  to  some  animal  populations  due  to  a 
decrease  in  habitat  diversity  and,  in  particular,  a 
reduction  in  the  mature  and  old  growth 
components  of  the  forest.  Simplification  of 
habitats  due  to  intensive  forest  management 
practices  would  add  to  this  impact. 

Riparian  habitat  would  be  adequately  protected  by 
Alternatives  6,  8  or  9,  but  would  be  adversely 
impacted  by  all  other  alternatives.  Increases  in 
sediment  yield  in  Alternatives  1  through  3  and 
increases  in  water  temperature  in  Alternative  1 
would  negatively  impact  fish.  Fish  would  increase 
in  Alternatives  4,  6,  7,  8  and  9. 

Snag-dependent  wildlife  would  be  greatly  reduced 
in  the  long  term,  but  impacts  would  be  minimal  in 
the  short  term.  In  the  long  term,  elk  numbers  are 
expected  to  decline  in  all  alternatives  except  8.  Elk 
numbers  would  increase  in  the  short  term  in  all 
alternatives. 

There  would  be  no  known  adverse  impacts  to  any 
species  listed  by  the  Federal  Government  as 
threatened  or  endangered.  The  northern  spotted 


owl,  listed  by  the  State  of  Oregon  as  threatened, 
may  be  adversely  impacted  in  the  long  term  by  all 
alternatives  except  8. 

Recreation 

The  impacts  of  timber  management  operations 
would  be  both  beneficial  and  adverse,  depending 
on  the  recreational  experience  desired.  Visitor  use 
increases  or  reductions  may  occur  in  certain  areas 
as  a  result  of  impacts  to  specific  recreational 
experiences. 

Impacts  would  depend  upon  the  approach  taken  to 
meet  recreational  needs.  For  the  long  term, 
Alternative  5  would  fall  short  of  meeting  demand  in 
many  activities  with  identified  area  and  facility 
needs.  Alternative  1  emphasizes  those  activities 
having  minimal  impact  on  the  commercial  timber 
base  and  would  not  provide  for  new  developed 
sites.  Alternatives  2,  3,  4,  7,  and  9  provide  a  variety 
of  opportunities  to  meet  most  needs.  Alternatives  6 
and  8  emphasize  dispersed  activities,  natural  areas 
and  the  opportunity  for  site  development,  although 
Alternative  8  would  not  meet  the  need  for  off-road 
vehicle  areas  and  trails.  In  the  long  term,  area-wide 
elk  hunting  opportunities  are  expected  to  be 
adversely  impacted  under  all  alternatives  except  6 
and  8,  while  fishing  opportunities  are  expected  to 
be  adversely  impacted  under  Alternatives  1 
through  3. 

Cultural  Resources 

Appropriate  measures  would  be  taken  to 
identify  and  protect  cultural  sites  prior  to  ground- 
disturbing  activities  under  all  alternatives. 
Undiscovered  cultural  sites  would  be  susceptible 
to  considerable  alteration  and  damage.  Once  a  site 
is  found,  however,  mitigation  measures  will  be 
instituted  to  minimize  or  avoid  damage.  Under  all 
alternatives,  significant  sites  identified  before, 
during  and  after  logging  would  be  managed  to 
protect  scientific  and/or  interpretive  values. 

Visual  Resources 

Under  Alternative  8,  visual  resource 
conditions  (scenic  quality)  would  improve.  Under 
Alternative  6,  most  highly  scenic  and/or  sensitive 
areas  would  be  protected  with  slight  adverse 
impacts  in  some  areas  of  the  SYUs.  Adverse  visual 
impacts  under  Alternatives  2,  3,  4,  7,  and  9  would 
be  low  to  moderate.  Many  highly  scenic  and/or 
sensitive  areas  would  be  protected. 

Under  Alternatives  1  and  5,  adverse  visual  impacts 
would  be  high  with  some  protection  provided  for 
certain  highly  scenic  and/or  sensitive  areas, 
primarily  essential  bald  eagle  habitat  and  existing 
recreation  sites. 


Areas  of  Critical  Environmental 
Concern 

Area  of  Critical  Environmental  Concern 
(ACEC)  designation  would  provide  guidelines  to 
help  achieve  resource  protection  in  those  areas 
designated.  All  alternatives  except  5  provide  some 
level  of  ACEC  designation  greater  than  the 
existing  situation.  Designation  ranges  from  four 
areas  (600  acres)  under  Alternative  1  to  seven 
areas  (3,100  acres)  under  Alternatives  6  and  8. 

Special  Areas 

Alternative  1  allows  for  designation  of 
those  areas  which  would  not  affect  the  commercial 
timber  production  base  of  the  SYUs.  Alternatives 
2,  3,  4,  7,  and  9  allow  for  designation  of  those 
areas  identified  as  having  significant  natural  values 
for  science,  recreation  or  education.  Alternative  5 
provides  no  additional  natural  area  designation 
above  that  under  the  existing  situation. 
Alternatives  6  and  8  emphasize  the  study  and 
designation  of  natural  areas.  However,  some  sites 
(e.g.,  Red  Pond,  Dompier  Creek  Landslide)  with 
natural  and  environmental  education  values  may 
be  adversely  impacted  if  they  are  not  designated 
or  otherwise  protected. 

Human  Health 

The  possibility  of  human  health  being 
impacted  by  the  use  of  herbicides  is  related  to  the 
toxicity  of  the  herbicide,  the  likelihood  of 
exposure,  and  resulting  dosage  received.  Based  on 
current  knowledge  and  the  low  risk  of  exposure  on 
BLM-treated  acres,  an  unreasonable  risk  to  human 
health  from  continued,  careful  use  of  herbicides  is 
unlikely.  Herbicides  would  not  be  used  under 
Alternative  7. 


Energy  Use 


Fossil  fuel  energy  would  be  consumed  in  all 
phases  of  the  10-year  timber  management  plan. 
The  annual  energy  consumption  ranges  from  218 
billion  Btu's  (Alternative  8)  to  834  billion  Btu's 
(Alternative  1).  The  annual  energy  consumption 
attributable  to  the  New  Preferred  Alternative 
(Alternative  9)  would  be  approximately  716  billion 
Btu's. 

Socioeconomics 

Compared  to  timber  harvest  levels  in  Douglas 
County  from  1976-1980,  Alternatives  1  through  5 
and  9  would  increase  employment  in  the  timber 
industry  and  total  local  employment  and  earnings. 
The  New  Preferred  Alternative  (Alternative  9) 
could  result  in  an  increase  of  440  timber  industry 
jobs  and  1,023  jobs  in  total.  The  greatest  increase 
in  jobs  would  be  the  result  of  Alternative  1 , 
yielding  751  timber  industry  jobs  and  1,746  total 
jobs.  Alternative  8  would  result  in  a  net  loss  of  766 
timber  industry  jobs  and  1,780  total  jobs. 


Compared  with  continuation  of  the  current  timber 
management  program,  Alternatives  1  through  4 
and  9  add  economic  activity.  In  this  comparison, 
the  New  Preferred  Alternative  (Alternative  9)  would 
add  340  timber  industry  jobs  and  791  jobs  in  total. 
At  the  extremes,  Alternative  1  could  stimulate  up 
to  1,514  new  jobs  while  Alternative  8  could  impact 
the  regional  economy  by  a  reduction  of  2,012  jobs. 

Public  revenues  would  be  increased  or  maintained 
for  Alternatives  1  through  5  and  9  and  decline  for 
Alternatives  6  through  8. 


Table  of  Contents 


Page 

Summary 3 

Chapter  1  Description  of  Alternatives  Including  the  Proposed  Action  11 

Purpose  of  and  Need  for  the  Action   11 

Alternatives 12 

Alternative  1  -  Maximum  Timber  Production   13 

Alternative  2  -  Strong  Emphasis  on  Timber  Production 13 

Alternative  3  -  Lower  Average  Minimum  Harvest  Size 13 

Alternative  4  -  The  Original  Proposed  Action 15 

Alternative  5  -  No  Action 15 

Alternative  6  -  Habitat  Diversity  15 

Alternative  7  -  No  Herbicides,  Fertilizer  or  Allowable  Cut  Effect  for  Genetics  15 

Alternative  8  -  Emphasis  on  Protection  of  Natural  Values 15 

Alternative  9  -  New  Preferred  Alternative 16 

Forest  Management  Treatments  and  Design  Elements 16 

Transportation  System  17 

Timber  Harvest  17 

Site  Preparation 17 

Planting 19 

Plantation  Protection 19 

Plantation  Maintenance  and  Release  19 

Precommercial  Thinning 20 

Fertilization 20 

Comparison  of  Impacts 20 

Implementation 20 

Final  Decision   20 

Monitoring  and  Studies 20 

Requirements  for  Further  Environmental  Assessment 22 

Interrelationships  22 

Federal  Agencies 22 

State  and  Local  Governments 23 


8 

Page 

Chapter  2  Affected  Environment 27 

Climate  and  Air  Quality 28 

Geology  and  Topography 29 

Soils  29 

Water  Resources 30 

Vegetation 35 

Terrestrial  Vegetation   35 

Wetland  and  Aquatic  Vegetation   38 

Sensitive,  Threatened  and  Endangered  Plants 38 

Animals  39 

Terrestrial  Animals 39 

Fish 41 

Threatened  and  Endangered  Animals 42 

Recreation 43 

Cultural  Resources 43 

Prehistoric  Sites  44 

Historic  Sites  44 

Paleontologic  Sites 44 

Visual  Resources 45 

Wilderness  Values 45 

Areas  of  Critical  Environmental  Concern 45 

Special  Areas 45 

Socioeconomic  Conditions 46 

Timber  Industry 53 

Fishing,  Hunting  and  Other  Recreation  53 

Social  Concerns  53 

Chapter  3  Environmental  Consequences 59 

Introduction 59 

Impacts  on  Air  Quality 60 

Conclusions 61 

Impacts  on  Soils 61 

Conclusions 63 

Impacts  on  Water  Resources 63 

Water  Quantity 63 

Water  Quality 63 

Municipal  Watersheds 65 

Conclusions 65 

Impacts  on  Vegetation 65 

Terrestrial  Vegetation   66 

Threatened  or  Endangered  Plants 67 

Conclusions 68 

Impacts  on  Animals 68 

Terrestrial  Vertebrates 68 

Fish 74 

Threatened  and  Endangered  Animals 75 

Conclusions 76 

Impacts  on  Recreation 77 

Conclusions 78 

Impacts  on  Cultural  Resources 78 

Conclusions 79 

Impacts  on  Visual  Resources 79 

Impacts  on  Areas  of  Critical  Environmental  Concern  81 

Impacts  on  Special  Areas 81 

Impacts  on  Energy  Use 81 

Impacts  to  Human  Health 82 

Impacts  on  Socioeconomic  Conditions 84 

Chapter  4  Consultation  and  Coordination  of  the  Draft 

Environmental  Impact  Statement 89 

Statement  89 

List  of  Agencies,  Organizations  and  Persons  to  Whom  Copies  of  the  Statement  are  Sent 149 

List  of  Preparers  1 50 

Appendices 153 


9 

Page 

Glossary 1 89 

References  Cited 197 

Index 205 


Tables 


1-1     Land  Jurisdiction  in  Acres  by  County  within  Roseburg  Sustained  Yield  Units 13 

1-2     Comparison  of  Proposed  Action  and  Alternatives  by  Treatment  —  First  Decade 14 

1-3     Derivations  of  Timber  Production  Base  Acreage 14 

1-4     Estimated  Ten-Year  Use  of  Herbicides 18 

1-5     Summary  of  Impacts 21 

1-6     Relationship  of  Roseburg  EIS  Alternatives  to  LCDC  Statewide  Goals 24 

1-7     Consistency  of  the  Roseburg  Alternatives  with  the  Basic  Objectives  of  the  Forestry  Program 

for  Oregon 25 

1-8     Consistency  of  the  Alternative  with  State  of  Oregon  Wildlife  Goals 26 

2-1     Total  Suspended  Particulates  in  Roseburg 28 

2-2     Slash  Smoke  Problems  in  Douglas  County 29 

2-3     Bared  Soils  and  Rose  Surfaces 30 

2-4     Fragile  and  Problem  Soils  30 

2-5     Severe  Water  Quality  Problems  35 

2-6     Streamf  low  Data 36 

2-7     Sediment  Discharge  Data 37 

2-8     Existing  Forest  Habitat  Stratification  of  Entire  Roseburg  Area 38 

2-9     Sensitive  Species  Currently  under  Review  for  Possible  Listing 39 

2-10  Habitat  Structure  of  Forest  Lands  in  the  SYUs 40 

2-1 1   Salmonoid  Fish  and  Habitat  Populations 42 

2-12  Threatened  and  Endangered  Species  of  the  SYUs 42 

2-13  Estimated  Current  and  Projected  Visitation  Attributed  to  Major  Recreation  Activities 44 

2-14  Nominated  and  Potential  Areas  of  Critical  Environmental  Concern  46 

2-15  Population,  1960-1980 49 

2-16  Components  of  Population  Change,  1970-1980 49 

2-17  Average  Size  and  Recent  Growth  of  the  Labor  Force  and  Employment  in  Industries  50 

2-18  Total  and  Rate  of  Growth  of  Labor  and  Proprietors'  Income  in  Selected  Industries 

Affected  by  Timber  Management  in  the  Roseburg  District 50 

2-19  County  Revenue  Sources  as  a  Percentage  of  Total  Revenues  and  County  Revenues 

Per  Capita  for  Fiscal  Years  1977-1978 51 

2-20  O&C  Revenue  Distribution  to  Counties  Expressed  as  Property  Tax  Rate  Equivalent 

and  as  a  Percent  Supplement  to  Total  Levy,  Fiscal  Years  1977-1980 52 

2-21   In-Lieu  Tax  Payment  on  CBWR  Lands  Administered  by  BLM  in  Douglas  County 52 

2-22  Timber  Harvest  by  Ownership  Class,  Douglas  County 53 

2-23  Dependency  of  Log  Processors  in  Oregon  and  Douglas  County  on  BLM  Timber 54 

2-24  Harvest  Sales  and  Receipts,  BLM  Timber  in  the  Roseburg  District 54 

2-25  Average  Annual  Local  Economic  Effects  of  Timber  Management  on  Lands 

Administered  by  the  Roseburg  District 55 

2-26  Local  Economic  Effects  of  Fisheries,  Terrestrial  Wildlife  and  General  Recreation  56 

2-27  Changes  Desired  by  Survey  Respondents  in  the  Use  of  Federal  Lands 57 

3-1     Average  Emission  Components  from  Slash  Burning 61 

3-2     Estimated  Loss  of  Productivity  During  First  Decade  62 

3-3     Expected  Nutrient  Losses  from  Timber  Harvesting  and  Slash  Burning  62 

3-4     Estimated  Annual  Water  Yield  from  BLM-Administered  Land,  End  of  First  Decade 63 

3-5     Estimated  Sediment  Through  Buffer  Strips 64 

3-6     Estimated  Sediment  Yield  from  BLM-Administered  Land,  End  of  Decade 65 

3-7     Proposed  Activities  in  Municipal  Watersheds  Based  on  the  Sample  Five  Year 

Timber  Sale  Plan 65 

3-8     Approximate  Acres  of  BLM-Administered  Timber  Lands  and  Percent  of  Change 

after  One  Decade  66 

3-9     Acres  of  Old  Growth  and  Percent  Change  from  Existing  on  BLM-Administered  Lands 

Remaining  at  the  End  of  Each  Decade 69 

3-10  Estimated  Elk  Population  Changes  on  BLM-Administered  Lands  in  the  Tyee  Area 71 

3-1 1   Long-Term  Snag  Density 72 

3-12  VRM  Classes  80 

3-13  Potential  Impacts  of  the  Sample  Five-Year  Timber  Sale  Plan  on  Visual  Resources  80 

3-14  Potential  Impacts  to  Areas  Qualified  for  ACEC  Designation 82 


10 

Page 

3-15  Potential  Impacts  to  Special  Areas  82 

3-16  Estimated  Annual  Energy  Consumption  83 

3-17  Herbicide  Toxicity  83 

3-18  Short-Term  Impacts  Compared  to  No  Action  Condition  on  Local  Employment  and 

Earnings  Related  to  Timber  Harvest 85 

3-19  Projected  Distribution  of  O&C  Payments  from  SYUs  to  Counties  by  Alternative  86 

3-20  Projected  Distribution  of  Severance  Taxes  on  CBWR  Lands  by  Alternative 86 


Figures 


Vicinity  Map 7 

1-1   Roseburg  SYU-EIS  Area Inside  Back  Pocket 

2-1   Physiographic  Province  31 

2-2  General  Soils 33 

2-3  Visual  Resource  Management 47 

2-4  Annual  Average  Lumber  and  Wood  Products  Employment;  Douglas  County,  Oregon  1970-1980 56 

A-1  Western  Oregon  Tree  Seed  Zones  157 

C-1  Allowable  Cut  Effect 171 

C-2  Allowable  Cut  Determination  Process 172 


11 


Chapter  1  Description  of 
Alternatives  Including  the 
Proposed  Action 


Purpose  of  and  Need  for  the 
Action 

The  Bureau  of  Land  Management  (BLM)  proposes 
to  implement,  beginning  October  1,  1983,  an 
updated  10-year  timber  management  plan  for  the 
and  South  Umpqua  Sustained  Yield  Units  in  the 
Roseburg  Douglas  District,  Oregon  (Figure  1-1, 
folded  map  in  the  back  cover  pocket).  The 
Douglas  and  South  Umpqua  Sustained  Yield  Units 
will  be  referred  to  in  this  document  as  Roseburg 
Sustained  Yield  Units  (SYUs).  These  are  primarily 
revested  Oregon  and  California  Railroad  (O&C) 
and  reconveyed  Coos  Bay  Wagon  Road  (CBWR) 
grant  lands.  There  are  also  scattered  remnants  of 
the  original  Public  Domain  (PD)  lands.  In 
accordance  with  the  National  Environmental 
Policy  Act  (NEPA),  this  EIS  identifies  impacts  on 
the  natural  and  human  environment  associated 
with  nine  alternatives.  The  10-year  timber 
management  plan  for  the  two  SYUs  provides 
direction  for  management  of  these  lands  as 
required  by  the  acts  mentioned  below. 

The  Bureau's  principal  authority  and  direction  to 
manage  the  O&C  and  CBWR  grant  lands  is  found 
in  the  O&C  Act  of  1937  (50  Stat.  874;  43  U.S.C. 
1181a.,  et  seq.).  The  disposition  of  funds  derived 
from  the  CBWR  grant  lands  is  described  in  an  act 
approved  on  May  24,  1939  (43  U.S.C.  1181f-l  et 
seq.).  Under  these  acts,  O&C  and  CBWR  lands 


12 


classified  as  timberlands  are  to  be  managed  under 
sustained  yield  principles  in  order  to  provide  a 
permanent  source  of  timber  supply,  watershed 
protection,  stream  flow  regulation  and  recreational 
facilities.  Intermingled  PD  lands  were  brought 
under  sustained  yield  management  principles  by 
the  Bureau's  1962  application  to  withdraw  these 
lands  from  entry  under  all  public  land  laws  except 
certain  disposal  acts.  Withdrawal  was  completed 
by  Public  Land  Order  5490  in  1975  (40  FR  7450).  In 
addition,  many  activities  of  the  BLM  are  governed 
by  the  Federal  Land  Policy  and  Management  Act 
of  1976  (90  Stat.  2743,  43  U.S.C.  1701).  This  law, 
often  referred  to  as  FLPMA,  established  policy  for 
BLM  administration  of  public  lands  under  its 
jurisdiction. 

Notwithstanding  any  provision  of  FLPMA,  in  the 
event  of  conflict  with  or  inconsistency  between 
FLPMA  and  the  O&C  Act  of  August  28,  1937  (50 
Stat.  874;  43  U.S.C.  1181a-1181j),  and  the  Act  of 
May  24,  1939  (43  USC  1181M  et  seq.),  insofar  as 
they  relate  to  management  of  timber  resources 
and  disposition  of  revenues  from  lands  and 
resources,  the  1937  and  1939  acts  shall  prevail. 

The  O&C  Forest  Resources  Policy  to  be  used  in 
formulating  decisions  for  BLM-administered  forest 
lands  in  western  Oregon  was  approved  by  the 
Director  in  March  1983.  A  copy  of  the  policy  is 
included  in  this  EIS  in  Appendix  A.  To  respond  to 
the  policy,  an  additional  alternative  has  been 
included  in  this  FEIS  and  is  designated  BLM's  New 
Preferred  Alternative  (Alternative  9). 

During  an  EIS  scoping  meeting  held  in  Roseburg, 
Oregon  (October  19,  1981),  participants  were 
asked  to  identify  issues  and  alternatives  to  be 
addressed  in  this  EIS.  Chapter  1  includes 
alternatives  identified  during  scoping  and 
considered  appropriate  for  full  analysis. 
Alternatives  identified  but  not  considered 
appropriate  for  full  analysis,  and  the  rationale  for 
these  determinations  are  presented  in  Appendix  B, 
which  summarizes  the  scoping  meeting.  A 
discussion  of  the  economic  efficiency  of  the 
timber  management  program  for  the  Original 
Proposed  Action  and  Alternative  9  (New  Preferred 
Alternative)  is  included  in  Appendix  B. 

During  the  planning  process,  criteria  (Appendix  C) 
were  used  to  evaluate  alternatives  and  select  a 
proposed  land  use  allocation  alternative.  The 
results  of  this  evaluation,  combined  with  public 
input,  led  to  the  original  proposed  land  use 
alternative,  Alternative  4  in  this  EIS. 

Appendix  C  also  addresses  inventory  methods 
used  to  arrive  at  the  timber  production  base, 
allowable  cut  determination  and  other  land  use 
allocations.  Acreages  for  land  use  allocations  by 
alternative  are  shown  in  Appendix  C,  Table  C-2. 


The  alternatives  prepared  for  the  SYUs  identify 
various  timber  harvest  levels,  management 
practices  and  mitigating  measures  to  protect  the 
land  and  other  resources.  This  information  is 
described  in  detail  in  the  remainder  of  this 
document. 

Alternatives 

Planning  for  the  Roseburg  Sustained  Yield 
Units  (SYUs)  focused  on  the  423,896  acres  of 
public  land  administered  by  BLM.  Except  for  280 
acres  in  Lane  County  and  400  acres  in  Jackson 
County,  all  lands  are  in  Douglas  County.  BLM 
administers  29  percent  of  the  total  land  within  the 
Roseburg  SYUs  (Table  1-1). 

There  are  nine  alternatives,  including  the 
Original  Proposed  Action  (Alternative  4)  and  the 
New  Preferred  Alternative  (Alternative  9),  for 
which  impacts  will  be  analyzed  in  Chapter  3: 

1.  Maximum  Timber  Production  (Max.  Tbr.) 

2.  Emphasis  on  Timber  Production  (Emp.  Tbr.) 

3.  Lower  Average  Minimum  Harvest  Size  (Lo  MHS) 

4.  Original  Proposed  Action  (OPA) 

5.  No  Action 

6.  Habitat  Diversity  (HD) 

7.  No  Herbicides,  Fertilizer  or  Allowable  Cut  Effect 
for  Genetics  (No  Herb.) 

8.  Emphasis  on  Protection  of  Natural  Values  (Full 
Eco.) 

9.  New  Preferred  Alternative  (NPA) 

For  each  alternative,  a  sustained  yield  harvest  level 
(allowable  cut)  has  been  calculated  based  on  the 
combined  timber  production  base  (see  Glossary) 
of  the  two  SYUs.  All  allowable  cut  computations 
are  made  in  cubic  feet  and  converted  to  Scribner 
board  feet  equivalence  for  the  first  decade.  There 
is  no  surplus  inventory  (see  Glossary).  Variables 
between  alternatives  include  amounts  of  land 
allocated  to  timber  production,  types  and  amounts 
of  intensive  management  practices  and  constraints 
on  timber  harvest  to  benefit  other  resource  values. 
These  relationships  are  displayed  in  Table  1-2. 
Treatments  and  design  elements  applicable  to 
each  alternative  are  discussed  in  the  Forest 
Management  Treatments  and  Design  Elements 
section  of  this  chapter. 

All  harvest  levels  shown  in  Table  1-2  are  computed 
on  the  respective  combinations  of  intensive  and 
constrained  timber  production  bases.  Table  1-3 
displays  the  breakdown  by  category  and 
alternative.  On  areas  allocated  to  constrained 
timber  production  (see  Glossary),  minimum 
harvest  ages  (MHA)  vary  to  recognize  specific 
needs  for  wildlife  habitat  diversity  and  visual 
resource  management  (VRM)  considerations.  The 
timber  production  base,  for  all  alternatives  except 
Alternative  5,  excludes  fragile  site  and 
reforestation  problem  withdrawals  (approximately 
1 1 ,000  acres)  and  a  minimum  of  4,448  acres  of 
commercial  forest  land  withdrawn  to  protect 


Table  1-1  Land  Jurisdiction  in  Acres1  by  County  within  Roseburg 
Sustained  Yield  Units 


13 


BLM2 

U.S.  Forest 
Service 

State 

Local  Govt. 
&  Private 

Total 

280 

0 

0 

0 

280 

400 

0 

0 

0 

400 

423,216 

978 

3,948 

1,032,150 

1,460,292 

423,8963 

978 

3,948 

1,032,150 

1,460,972 

County 

Lane 
Jackson 
Douglas 
Totals 

'  Acreage  figures  for  BLM-administered  lands  are  derived  from  master  title  plats.  Other  acreage  figures  are  from  Resource  Atlases 
published  by  O.S.U.  Extension  Service,  1964. 

2  O&C  lands  make  up  93  percent  of  the  public  lands  administered  by  BLM.  PD  and  CBWR  lands  comprise  the  remaining  4  and  3  percent, 
respectively. 

3  Refer  to  Appendix  C,  Table  C-2. 


certain  natural  and  cultural  resources.  Appendix  C 
explains  these  withdrawals  in  more  detail 
(Appendix  C,  Table  C-2). 

Alternatives  2,  3,  4,  7  and  9  include  modified  area 
control  (see  Appendix  C),  which  is  a  process  for 
managing  a  given  number  of  acres  under  a  special 
timber  harvest  regime.  In  the  Roseburg  SYUs, 
52,047  acres  are  planned  to  be  managed  under  the 
modified  area  control  concept  for  Alternatives  3,  4 
and  7,  35,868  acres  for  Alternative  9  and  24,786 
acres  for  Alternative  2.  These  acres  are  primarily 
managed  for  riparian,  spotted  owl,  old  growth  and 
visual  values  and  are  generally  located  within  a 
corridor.  This  process  would  yield  a  timber  harvest 
of  approximately  4  MM  bd.  ft.  in  Alternative  2,  6 
MM  bd.  ft.  in  Alternative  9  and  9  MM  bd.  ft.  in 
Alternatives  3,  4  and  7.  Harvest  methods  would 
vary,  ranging  from  clearcut  to  individual  tree 
selection. 

Alternative  1  -  Maximum 
Timber  Production 

Timber  production  would  be  maximized  while 
meeting  legal  requirements  to  protect  federally 
listed  threatened  and  endangered  species  and 
cultural  resources.  This  alternative  would  allocate 
386,622  acres  to  intensive  timber  management  and 
provide  an  annual  timber  sale  program  of  289  MM 
bd.  ft.  through  accomplishment  of  various 
intensive  timber  management  practices  (see  Table 
1-2).  Lands  not  allocated  to  timber  production 
(4,448  acres)  would  be  managed  for  other 
resources  such  as  cultural,  established  recreation 
sites  and  threatened  and  endangered  species. 
Timber  available  for  final  harvest  would  have  an 
average  size  of  12.7  inches  dbh,  normally  reached 
in  40  years.  Harvest  at  this  size  would  occur  during 
the  5th  through  17th  decades  of  the  400-year 
projection  period. 


This  alternative  provides  for  harvest  of  stream 
buffers  consistent  with  the  Oregon  Forest 
Practices  Act;  however,  specific  protection  for 
riparian  zones,  wetlands  and  northern  spotted 
owls  would  not  be  provided. 

Alternative  2  -  Strong  Emphasis 
on  Timber  Production 

Under  this  alternative,  360,580  acres  of 
commercial  forest  land  would  be  allocated  to 
intensive  timber  management  with  an  additional 
24,786  acres  managed  under  modified  area  control 
(Appendix  C).  This  would  provide  an  annual 
timber  sale  program  of  267  MM  bd.  ft.  Stream 
buffers  averaging  200  feet  wide  would  be  provided 
on  third  order  or  greater  streams  managed  under 
modified  area  control.  Approximately  5,700  acres 
of  commercial  forest  land  would  be  withdrawn 
from  the  allowable  cut  base  to  provide  for  other 
resource  uses  (Appendix  C,  Table  C-2).  Timber 
available  for  final  harvest  in  the  intensive  timber 
base  would  have  an  average  size  of  14.4  inches 
dbh,  normally  reached  in  50  years.  Harvest  at  this 
size  would  occur  from  the  5th  through  10th 
decades  during  the  400-year  projection  period. 

Alternative  3  -  Lower  Average 
Minimum  Harvest  Size 

Allocation  of  333,319  acres  of  commercial 
forest  land  to  intensive  timber  management  would 
occur  under  this  alternative.  An  additional  52,047 
acres,  including  an  average  200-foot  buffer  on 
third  order  and  greater  streams  and  selected  VRM 
lands  and  wildlife  habitat,  would  be  managed 
under  modified  area  control  (Table  1-3  and 
Appendix  C,  Table  C-4).  This  would  produce  an 
average  timber  sale  program  of  256  MM  bd.  ft. 
annually.  Approximately  5,700  acres  of 
commercial  forest  land  would  be  withdrawn  from 
the  allowable  cut  base  to  provide  for  other 
resource  uses. 


14 


Table  1-2  Comparison 

of  Alternatives  by  Treatment  -  First  Decade 

Alt.  1 

Alt.  2 

Alt.  3 

Alt.  4 

Alt.  5 

Alt.  6 

Alt.  7 

Alt  8 

Alt.  9 

Max. 

Emp 

Lo 

No 

No 

Full 

Tbr. 

Tbr. 

MHS 

OPA 

Action 

HD 

Herb. 

Eco. 

NPA 

Intensive  Timber 

Production  Base'  (acres) 

386.622 

360.580 

333.319 

333.319 

377.098 

222.357 

261  191 

0 

331.637 

Constrained  Timber 

Production  Base'  (acres) 

0 

24.786 

52.047 

52.047 

13.886 

119.924 

52.047 

262,436 

35.868 

Annual  Harvest 

Total  Million  bd  ft 

289 

267 

256 

249 

201 

183 

176 

84 

247 

Total  Million  cu  It 

47  46 

4381 

4203 

41  00 

3303 

30  28 

28  94 

1383 

40  47 

Treatments2 

Transportation  System  (miles. acres) 

New  Construction ' 

928:5.568 

854,5.124 

822:4,932 

800;4,800 

616:3.696 

588.3,528 

551:3,306 

277, 1,662 

794.4.764 

Reconstruction 

641;         0 

590;        0 

568.         0 

552:        0 

425:         0 

406.         0 

381;        0 

191:         0 

548;         0 

Timber  Harvest  (acres) 

Clearcut 

66.780 

61,411 

59.152 

57.548 

44.294 

42.298 

39,659 

19.915 

57.093 

Mortality  Salvage 

4.138 

3,830 

3,325 

3,347 

21.949 

2.362 

2.646 

0 

3.328 

Commercial  Thinning 

3,889 

3.611 

3.479 

3.479 

7,357 

2.778 

2.802 

0 

1.383 

Site  Preparation  (acres) 

Broadcast  Burning 

(slash  disposal) 

52,088 

47.901 

46.139 

44,887 

34.549 

32.992 

30,659 

15.534 

44.532 

Herbicide 

60.770 

55.884 

53,828 

52,369 

40,308 

38.491 

0 

18.123 

51  955 

Manual 

2.003 

1,842 

1.775 

1.726 

1,329 

1.269 

23,790 

597 

1.713 

Mechanical 

4.675 

4.299 

4.141 

4.028 

3.101 

2,961 

2,776 

1.394 

3,997 

Planting  (acres) 

Initial  plant' 

61,212 

56,287 

54.220 

52.748 

40,598 

38.770 

36.353 

18.253 

52.329 

Replant  or  Interplant 

18,364 

16.886 

16.266 

15,824 

12.179 

11.631 

10.906 

5.476 

15,698 

Plantation  Protection  (acres) 

36,061 

33,162 

31.942 

31,076 

23.919 

22.841 

21,416 

10.754 

30.830 

Plantation  Maintenance  and 

46,746 

42,988 

41.406 

40,284 

31.006 

29.609 

7,300 

13,940 

39.965 

Release-  (acres) 

Precommercial  Thinning  (acres) 

44.576 

42,240 

40.755 

40,755 

12.326 

31.370 

37.319 

0 

40,449 

Fertilization  (acres) 

61.270 

57.984 

56,029 

56,029 

0 

43.659 

0 

0 

55,646 

1  See  Glossary. 

2  Each  treatment  is  described  in  detail  following  description  of  the  alternatives. 

1  Figured  at  the  rate  of  6  acres/mile  of  road  includi 

ing  landings. 

J  Under  all  alternatives  except  Alternati 

ve  8,  15,200  acres  would  be  planted 

with  genet 

ically  improved  stock. 

5  All  to  be  accomplished 

with  herbicides  except  in 

Alternative  7 

where  manual  methods  are  to  be 

employed 

exclusively. 

Table  1-3  Derivations  of  Timber  Production  Base  Acreage 

Alternatives  Including  the  Proposed  Action 

Alt.  1 
Max. 
Tbr. 

Alt.  2 
Emp. 
Tbr. 

All.  3 

Lo 
MHS 

Alt.  4 
OPA 

Alt.  5 

No 
Action 

Alt. 6 
HD 

Alt.  7 

No 
Herb. 

Alt.  8 
Full 
Eco. 

Alt.  9 
NPA 

INTENSIVE  TIMBER 
PRODUCTION  BASE 

386,622 

360,580 

333.319 

333,319 

377,098 

222.357 

261,191 

0 

331.637 

CONSTRAINED  TIMBER 
PRODUCTION  BASE 

VRM  (250  year  modified 

area  control) 
VRM  (MHA-130) 
Wildlife  (250  year 

modified  area  control) 
Wildlife  (MHA-60) 
Wildlife  (MHA-250) 
Wildlife  (MHA-350) 

0 

0 
0 

0 
0 
0 

3.682 

0 
21,104 

0 
0 
0 

2,646 

0 
49,401 

0 
0 
0 

2,646 

0 
49,401 

0 
0 
0 

0 

0 
0 

0 
0 
0 

0 

31.345 
0 

0 
76,359 
12,220 

2,646 

0 
49,401 

0 
0 
0 

0 

49.376 
0 

107.180 
83.211 
22.669 

2.658 

0 
33,210 

0 
0 
0 

TOTAL  CONSTRAINED 

0 

24.786 

52.047 

52.047 

13.886 

119,924 

52.047 

262.436 

35.868 

TOTAL  TIMBER 
PRODUCTION  BASE' 

386.622 

385.366 

385.366 

385,366 

390,984 

342.281 

313,238 

262.436 

367.505 

'  Refer  to  Land  Use  Allocati 

on.  Append 

ix  C,  Table  C-2 

15 


Timber  stands  available  for  final  harvest  in  the 
intensive  timber  base  would  have  an  average  size 
of  12.7  inches  dbh,  normally  reached  in  40  years. 
In  actuality,  harvest  at  this  size  would  occur  from 
the  5th  through  the  28th  decades  during  the  400- 
year  projection  period.  A  regulated  forest  on 
intensive  timber  production  lands  would  be 
reached  in  about  the  30th  decade.  It  is  assumed 
that  by  the  time  a  regulated  forest  is  achieved,  the 
annual  harvest  level  from  the  lands  allocated  to 
timber  production  under  this  alternative  and  the 
Original  Proposed  Action  (Alternative  4)  could  be 
increased  to  the  highest  level  sustainable  from  this 
timber  management  base  (estimated  to  be 
approximately  303  MM  bd.  ft.). 

Alternative  4  -  The  Original 
Proposed  Action 

This  alternative  allocates  the  same  acreages 
to  timber  and  other  resource  management  as 
Alternative  3.  However,  timber  available  for  final 
harvest  in  the  intensive  timber  base  would  have  an 
average  size  of  14.4  inches  dbh,  normally  reached 
in  50  years.  This  would  produce  an  average  annual 
timber  sale  program  of  249  MM  bd.  ft.  Harvest  at 
this  size  would  occur  from  the  4th  through  the 
10th  decades  during  the  400-year  projection 
period.  A  regulated  forest  on  intensive  timber 
production  lands  would  be  reached  in  about  13 
decades.  Management  elements  would  be  identical 
to  those  in  Alternative  3  (see  Tables  1-2,  1-3  and 
Appendix  C,  Tables  C-3,  C-4). 

Alternative  5  -  No  Action 

Alternative  5  constitutes  a  continuation  of 
the  present  allowable  cut  of  201  MM  bd.  ft.  from 
390,984  acres  allocated  to  timber  production. 
Continuation  of  the  same  management  practices, 
level  of  application  and  constraints  used  in  the 
1972  allowable  cut  calculation  is  assumed. 
Management  trends  (such  as  reduced  tractor 
yarding)  established  over  the  past  decade  would 
be  continued.  Minimal  protection  would  be 
provided  for  some  highly  scenic  areas, 
recreational  sites  and  wildlife  habitat.  Non-timber 
allocations,  limited  to  400  acres,  include  buffers 
for  recreation  areas  and  sensitive  visual  corridors. 
Streamside  buffers  totaling  8,070  acres  would  be 
provided  along  third  order  and  larger  streams 
(Table  C-4).  Other  land  use  allocations  (Appendix 
C,  Table  C-2)  and  management  objectives  (Table 
1-2)  proposed  under  this  alternative  are  those 
incorporated  in  the  1972  Timber  Management  Plan 
for  its  second  decade  of  application. 

Alternative  6  -  Habitat  Diversity 

Protection  of  some  natural  and  cultural 
values,  while  accommodating  timber  production 
and  other  commodities,  would  be  provided  under 
Alternative  6.  It  would  allocate  222,357  acres  to 
intensive  forest  management  with  an  additional 
119,924  acres  managed  under  longer  harvest 


cycles.  The  annual  timber  sale  program  would  be 
183  MM  bd.  ft.  Timber  available  for  final  harvest  in 
the  intensive  timber  base  would  have  an  average 
size  of  14.4  inches  dbh,  normally  reached  in  50 
years.  Stream  buffers  at  least  250  feet  wide  would 
be  provided  on  third  order  and  greater  streams.  In 
addition,  48,790  acres  of  commercial  forest  land 
would  be  withdrawn  from  the  allowable  cut  base  to 
provide  for  other  resource  uses  (Appendix  C, 
Table  C-2). 

Alternative  7  -  No  Herbicides, 
Fertilizer  or  Allowable  Cut 
Effect  for  Genetics 

This  alternative  differs  from  Alternative  4 
in  that  the  forest  management  treatments  of 
herbicide  and  fertilizer  applications  would  not  be 
incorporated.  Without  the  use  of  herbicides  to 
control  competing  vegetation,  approximately 
72,100  acres  would  be  withdrawn  from  the  timber 
production  base  due  to  reforestation  problems. 
Control  of  vegetation  for  timber  management  by 
using  biological,  mechanical  or  manual  means 
would  be  prescribed  to  approximately  the  same 
dollar  level  of  investment  as  would  be  used  for 
herbicide  and  fertilizer  applications  in  Alternative  4 
to  provide  a  means  of  comparison. 

Alternative  7  would  provide  for  continued  planting 
of  genetically  improved  trees,  but  the  allowable  cut 
computation  would  not  take  credit  for  expected 
growth  increases.  This  would  produce  an  average 
annual  timber  sale  program  of  176  MM  bd.  ft. 
Timber  available  for  final  harvest  in  the  intensive 
timber  management  base  would  have  an  average 
size  of  13.6  inches  dbh,  normally  reached  in  50 
years. 

Alternative  8  -  Emphasis  on 
Protection  of  Natural  Values 

In  this  alternative,  protection  would  be 
provided  for  a  variety  of  wildlife  habitats,  sensitive 
botanical  species,  visual  resources,  research 
natural  areas,  riparian  areas  and  dispersed 
recreational  activity  areas.  Unharvested  stream 
buffers,  varying  in  width  by  stream  order  from  150 
to  500  feet,  would  be  provided  on  all  streams.  This 
is  considered  to  be  a  full  ecosystem  alternative. 

No  land  would  be  included  in  the  intensive  timber 
base.  Treatments  not  planned  for  Alternative  8  are 
mortality  salvage,  commercial  and  precommercial 
thinning,  fertilization  and  genetically  improved 
stock  (Table  1-2).  Approximately  262,436  acres  of 
commercial  forest  land  would  be  included  in  the 
constrained  timber  base  (Table  1-3).  Minimum 
harvest  age  varies  from  60  years  to  350  years.  This 
would  produce  an  average  timber  sale  program  of 
84  MM  bd.  ft.  annually.  Fifteen-year  spacing 
between  adjacent  harvest  areas  would  be 
employed.  In  addition,  128,634  acres  of 


16 


commercial  forest  land  would  be  withdrawn  from 
the  allowable  cut  base  to  protect  non-timber 
resource  values  (Appendix  C,  Table  C-2).  Harvest 
from  these  areas  would  be  allowed  only  when  of 
direct  benefit  to  the  protected  resources. 

Alternative  9  -  New  Preferred 
Alternative 


This  alternative  seeks  a  high  level  of 
timber  production  while  managing  for  a  variety  of 
natural  values  and  recreation  opportunities.  This 
alternative  is  similar  to  Alternative  4,  except  that 
18,332  acres  of  riparian  area  along  third  order  and 
greater  streams  would  be  withdrawn  from  the 
allowable  cut  base. 


Under  this  alternative  331,637  acres  of  commercial 
forest  land  would  be  allocated  to  intensive  timber 
management  with  an  additional  35,868  acres 
managed  under  modified  area  control.  This  would 
produce  an  average  annual  timber  sale  program  of 
247  MM  bd.  ft.  Timber  available  for  final  harvest  in 
the  intensive  base  would  have  an  average  size  of 
14.4  inches  dbh,  normally  reached  in  50  years. 
Harvest  at  this  size  would  occur  from  the  4th 
through  the  10th  decades  during  the  400-year 
projection  period.  A  regulated  forest  on  intensive 
timber  production  lands  would  be  reached  in 
about  13  decades.  An  additional  5,233  acres  of 
commercial  forest  land  would  be  withdrawn  from 
the  allowable  cut  base  to  provide  for  cultural  and 
botanical  resources,  bald  eagles  and  recreation 
sites  (Table  C-2). 

Forest  Management 
Treatments  and  Design 
Elements 


Table  1-2  displays,  in  typical  sequence,  the  types 
and  levels  of  treatments  for  each  alternative. 
Following  harvest  by  clearcut  or  single  tree 
selection,  these  treatments  are  used  to  achieve 
prompt  reforestation  and  to  increase  subsequent 
growth  of  commercial  coniferous  species.  The 
following  discussion  of  treatments  will  be  in  the 
same  order  as  listed  in  Table  1-2. 

Not  every  treatment  listed  in  Table  1-2  would  be 
applied  to  every  acre.  A  number  of  treatment 
combinations  are  possible  and  could  be  employed. 
The  purpose  of  this  section  is  to  elaborate  on  what 
each  treatment  entails  and  quantify  the  magnitude 
of  the  actions.  Treatments  would  be  identified  and 
scheduled  through  application  of  the  recently 
adopted  forest  data  system  (Solutions  to 
Operations  and  Reforestation  Monitoring  Systems- 
STORMS  1981).  For  those  actions  required  in 


timber  sale  contracts,  the  final  determination  of 
treatment  needs  would  be  made  during  timber  sale 
planning. 


Contracts,  usually  awarded  on  a  competitive  basis, 
are  the  means  of  accomplishing  all  timber  harvest 
and  many  forest  development  practices.  The 
standard  and  special  provisions  (which  include 
mitigating  measures)  in  a  contract  set  forth  the 
performance  standards  to  be  followed  by  the 
contractor  in  carrying  out  the  action  in  accordance 
with  applicable  laws,  regulations  and  policies.  In 
contract  preparation,  selection  of  special 
provisions  is  governed  by  the  scope  of  the  action 
to  be  undertaken  and  the  physical  characteristics 
of  the  specific  site.  The  standard  provisions  of  the 
basic  timber  sale  contract,  Bureau  Form  5450-3, 
are  applicable  for  all  timber  sales.  Limitations  on 
timber  harvesting  and  related  activities,  as 
identified  in  the  Church  Report  (U.S.  Congress, 
Senate  1973)  and  analyzed  in  the  BLM  Timber 
Management  -  Final  EIS-1975,  have  been  adopted 
by  BLM.  Bureau  manuals  and  manual  supplements 
provide  a  variety  of  approved  special  provisions  for 
use,  as  appropriate,  in  individual  contracts.  The 
combination  of  selected  special  provisions 
constitutes  Section  41  of  the  timber  sale  contract 
(Form  5450-3). 

Prior  to  any  vegetative  or  ground  manipulation, 
BLM  requires  a  survey  of  the  project  site  for  plants 
and  animals  listed  or  proposed  for  listing/as 
threatened  and  endangered  species.  If  a  project 
might  affect  any  federally  listed  or  proposed 
threatened  or  endangered  species  or  its  critical 
habitat,  every  effort  would  be  made  to  modify, 
relocate  or  abandon  the  project  in  order  to  obtain 
a  no  effect  determination.  If  BLM  determines  that  a 
project  cannot  be  altered  or  abandoned, 
consultation  with  the  U.S.  Fish  and  Wildlife  Service 
would  be  initiated  (50  CFR  402;  Endangered 
Species  Act  of  1973,  as  amended). 

Whenever  evidence  of  historic  or  prehistoric 
occupation  is  identified  during  BLM  activities, 
special  surveys  are  undertaken  to  determine 
possible  conflicts  in  management  objectives.  In 
addition,  a  Class  III  (complete)  cultural  resources 
inventory  is  required  on  all  areas  to  be  subjected 
to  ground  disturbing  activities.  This  is 
accomplished  in  the  pre-planning  stage  of  a 
treatment  and  the  results  analyzed  in  the 
environmental  assessment  addressing  the  action 
(BLM  Manual  8100,  Cultural  Resources 
Management).  When  a  cultural  resource  is 
discovered  during  timber  harvest  or  associated 
activities,  operations  in  proximity  are  immediately 
suspended  and  may  only  resume  upon  receipt  of 
written  instructions  from  the  authorized  BLM 
officer.  Procedures  under  36  CFR  800  would  then 
be  followed,  including  consultation  with  the  State 
Historic  Preservation  Officer  in  the  determinations 
of  eligibility  and  effects. 


17 


Transportation  System 

Oregon  Manual  Supplement,  Release  5-115  of 
April  10,  1975,  would  be  used  in  preparing  road 
construction  requirements  for  timber  sale 
contracts.  Engineering  terminology  and  types  of 
construction  equipment  are  defined  in  the  manual 
supplement  and  specifications  for  all  aspects  of 
construction,  reconstruction  and  surfacing  are 
provided. 

Methods  of  slope  protection  are  provided  to  avoid 
collapse  of  cut-and-fill  embankments. 
Specifications  for  rock  pits  and  quarries  include 
provisions  for  minimum  visual  intrusion,  drainage 
and  control  of  runoff  and  restoration  following 
use. 

Special  stipulations  are  provided  for  the 
installation  of  stream  crossing  structures,  such  as 
corrugated  metal  culverts,  so  that  fish  passage  is 
not  impeded.  These  measures  may  include 
imposing  gradient  limitations  for  the  structures 
and/or  installing  baffles  to  reduce  water  velocity 
through  the  culverts. 

One  section  of  the  manual  supplement  provides 
design  features  to  control  and  minimize  erosion 
during  road  construction  and  throughout  the 
design  life  of  the  road.  Another  section  addresses 
soil  stabilization  practices,  including  planting, 
seeding,  mulching  and  fertilizing  for  establishment 
of  soil-binding  vegetation. 

Road  reconstruction  is  proposed  for  all 
alternatives.  The  miles  of  road  to  be  reconstructed 
range  from  641  under  Alternative  1  to  191  miles 
under  Alternative  8  (Table  1-2).  Similarly,  the  miles 
of  new,  permanent  road  to  be  constructed  during 
the  decade  would  range  from  928  miles  under 
Alternative  1  to  277  miles  under  Alternative  8 
(Table  1-2).  Construction  standards,  i.e.,  stream 
crossing,  subgrade  width,  ditch,  cut-and-fill  slope 
requirements,  and  type  of  surfacing,  would  be 
determined  during  the  annual  timber  sale  planning 
process.  Basic  construction  operations  as  well  as  a 
brief  history  of  transportation  systems  are 
described  in  detail  in  the  programmatic 
environmental  impact  statement  BLM  prepared  on 
timber  management  in  the  western  United  States 
(USDI,  BLM  1975),  hereafter  referred  to  as  the 
BLM  Timber  Management  FEIS. 

Road  closures  are  planned  for  all  alternatives 
where  significant  impacts  to  wildlife  are  occurring 
or  likely  to  occur  as  a  result  of  uncontrolled 
vehicle  access. 

Timber  Harvest 

The  primary  timber  harvest  method  to  be 
employed  during  the  next  10-year  period  would  be 
clearcutting.  An  estimated  78  percent  of  the 
proposed  final  harvest  by  clearcutting  (see  Table 
1-2  for  proposed  acreages  by  alternatives)  would 


be  accomplished  by  high  lead  cable  yarding 
systems.  Another  9  percent  would  be 
accomplished  by  cable  yarding  systems 
specifically  providing  partial  log  suspension  and  5 
percent  providing  full  log  suspension.  The 
remaining  8  percent  would  be  harvested  by  tractor 
skidding,  of  which  19  percent  would  be 
accomplished  using  "low  ground  pressure" 
equipment.  This  variety  of  logging  systems  is  a 
design  feature  employed  primarily  for  watershed 
protection  and  reduced  soil  damage.  Refer  to  the 
BLM  Timber  Management  FEIS  for  a  detailed 
description  of  logging  systems. 

Timber  harvesting  limitations  pertaining 
specifically  to  clearcutting,  as  identified  in  the 
Church  Report  (U.S.  Congress,  Senate  1972),  have 
been  adopted  by  BLM.  These  limitations  are 
incorporated  in  the  Oregon  Manual  Supplement 
5424,  which  lists  special  provisions  or  stipulations 
for  use  in  the  logging  requirements  portion  of  a 
timber  sale  contract. 

Acreages  allocated  to  the  constrained  timber  base, 
including  those  managed  under  modified  area 
control,  would  be  harvested  by  individual  tree 
selection,  shelterwood  and/or  clearcutting 
methods.  (Also,  see  discussion  on  Modified  Area 
Control  in  Appendix  C.) 

Single  tree  selection  would  be  employed  for 
harvest  of  dead  and  dying  timber  (mortality 
salvage)  in  stands  not  scheduled  for  harvest  within 
the  10-year  period.  Mortality  salvage  would  take 
place  on  lands  in  the  intensive  timber  production 
base  and  on  all  other  lands  in  the  event  of  a  major 
catastrophic  event  or  when  beneficial  to  wildlife  or 
fish.  The  variance  in  acreages  proposed  for 
mortality  salvage  (Table  1-2)  reflects  the 
differences  in  over-mature  timber  available  under 
each  alternative. 

Commercial  thinning  would  be  applied  to 
intensively  managed  timber  stands  between  the 
ages  of  30  and  60  years.  The  interval  of  treatment 
(ranging  from  10  to  30  years)  would  vary 
according  to  site  characterization  with  poor  sites 
having  longer  intervals.  Acreages  proposed  for 
commercial  thinning  by  alternative  are  presented 
in  Table  1-2. 


Site  Preparation 


Site  preparation  procedures  are  used  to 
prepare  newly  harvested  and  inadequately  stocked 
areas  for  the  planting  of  a  new  crop  of  trees.  Four 
types  of  site  preparation  treatments  (broadcast 
burning,  herbicides,  mechanical  and  manual)  are 
planned  within  the  SYUs  for  the  proposal  period 
(Table  1-2). 

The  main  site  preparation  treatment  would  be 
broadcast  burning  to  control  competing 
vegetation,  provide  planting  site  accessibility  and 
reduce  the  fire  hazard.  Burning  would  occur  at 


18 


times  approved  by  the  Oregon  State  Department 
of  Forestry  which  administers  the  Smoke 
Management  portion  of  the  State's  Air  Quality 
Implementation  Plan.  Acreage  requiring  slash 
disposal  by  broadcast  burning  (Table  1-2)  may 
receive  one  or  more  of  the  following  site 
preparation  treatments. 


Site  preparation  treatment  using  herbicides  (Table 
1-4)  is  included  in  all  alternatives  except 
Alternative  7.  Herbicides  are  used  to  increase 
plantation  survival  rate  by  control  of  grasses, 
forbs,  brush  and  noncommercial  tree  species. 
These  treatments  improve  the  potential  for 
success  by  reducing  competition  for  light, 


Table  1-4  Estimated  Ten-Year  Use  of  Herbicides 

Chemical 

Method 

Season 

Carrier 

Target  Species 

Application 

Rate1 
(Ibs./Acre) 

Estimated  Ac 

res 

Alt.  1 
Max. 
Tbr. 

Alt.  2 
Emp. 
Tbr. 

Alt.  3 

Lo 
MHS 

Alt.  4 
OPA 

Alt.  5 

No 
Action 

Alt.  6        Alt. 
HD 

7-       Alt  8 
Full 
Eco. 

Alt.  9 
NPA 

SITE  PREPARATION 

Atrazine- 
Dowpon 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses 

4  lbs  ea 

33.302 

30.624 

29.498 

28.698 

22.089 

21.093 

9  931 

28  471 

Atrazine 
Dowpon- 
2.4D 

Aerial 

Spring 

Water 

Grasses,  lorbs.  brush 

•1  4  2  lbs 

4,315 

3.968 

3.822 

3,718 

2,862 

2.733 

1.287 

3.689 

Velpar 

Aerial 

Spring 

Water 

Grasses,  torbs 

1  lb 

6.563 

6,036 

5.813 

5,656 

4,353 

4.157 

1.957 

5.611 

Velpar 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses 
&  forbs 

2  lbs 

3,525 

3,241 

3.122 

3,037 

2,338 

2.233 

1.051 

3,013 

Roundup 
(Glyphosate) 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses 
&  forbs 

1  qt   (1  lb) 

425 

391 

377 

367 

282 

270 

127 

364 

Roundup 

Aerial 

Late 
Summer 

Water 

Deciduous  brush  &  hardwoods 

1-1  2  qls 
(1-1/2  lb.) 

8.812 

8.103 

7.805 

7.593 

5.845 

5,581 

2,628 

7.533 

Garlon  4 

Aerial 

Early 
Summer 

Water 

Brush  &  other  herbaceous 
vegetation 

4-8  lbs. 

912 

838 

807 

786 

605 

577 

272 

780 

Roundup 

Ground 
(back- 
pack) 

Spring 

Water 

Annual  &  Perennial  grasses 

1%  solution 
(1  Ib/ac. 
approx ) 

668 

615 

592 

576 

443 

423 

199 

571 

Roundup 

Ground 
(back- 
pack) 

Spring 

Water 

Annual  &  Perennial  grasses 
&  forbs 

2%  solution 
(1  lb  ac 
approx  I 

2.248 

2.068 

1,992 

1.938 

1.491 

1.424 

671 

1,923 

PLANTATION 
MAINTENANCE  & 
RELEASE 

Atrazine- 
Dowpon 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses 

4  lbs  ea. 

12.154 

11   177 

10,766 

10,474 

8.062 

7,698 

3,624 

10.391 

Atrazine 
Dowpon-2.4-D 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses, 
brush  &  hardwoods 

4/4/2  lbs. 

2.478 

2.278 

2.195 

2.135 

1.643 

1.569 

739 

2.118 

2.4-D 

Aerial 

Spring 

Water  & 
Oil 

Evergreen  brush  &  hardwood 
species,  Herbaceous 
vegetation 

3  lbs 

3,973 

3,654 

3,520 

3.424 

2.636 

2.517 

1,185 

3.397 

Roundup 

Aerial 

Late 
Summer 

Water 

Deciduous  brush  & 
hardwoods 

1    1  2  qts 

12.949 

11.908 

1 1 .469 

11.158 

8.589 

8.202 

3.861 

11.070 

Velpar 

Aerial 

Spring 

Water 

Annual  &  Perennial  grasses 
&  forbs 

1-2  lbs 

5.282 

4.857 

4,679 

4.552 

3.504 

3.346 

1.575 

4.516 

Asulox 

Aerial 

Late 
Summer 

Water 

Bracken  fern 

3,3  lbs 
(1  gal.) 

3.272 

3,009 

2.898 

2.820 

2,170 

2.073 

976 

2.798 

Garlon  4 

Aerial 

Spring 

Water  & 
Oil 

Evergreen  &  deciduous 
brush  &  hardwoods 

1-2  lbs. 

3.319 

3.053 

2.939 

2861 

2,201 

2,102 

990 

2.838 

Garlon  4 

Ground 

All 
Seasons 

Diesel 

Bigleaf  maple 
(Basal  Spray) 

1%  Solutton- 

1  gal    100  gal 

mix  (4  Ibs./ac 

approx  ) 

473 

456 

443 

341 

326 

153 

439 

Garlon  3A 

Hand 

All 
Seasons 

Dilute 

with 
water 

i  1 

Bigleaf  maple.  Madrone. 
Red  alder  (hack'squirt) 

1  ml  Solution 
per  inch  dia 

approx .) 

1.075 

989 

952 

927 

713 

681 

321 

920 

Tordon  101 R 

(picloram- 

2.4-D) 

Hand 

Spring 

None  un- 
diluted 

Madrone  &  other  hardwoods 

1  ml.  per  Inch 
dia 
lb   ac  ) 

1.590 

1.532 

1.490 

1   147 

1.095 

516 

1  478 

'  Active  ingredients  (in  total  pounds)  applied  may  be  figu 
alternative. 

red  by  mult 

iplying  the  application  rate  by  the 

estimated  acres  under  each 

*  Alternative  7  does  not  em 

ploy  the 

use  of  herbicides. 

19 


moisture  and  soil  nutrients  during  the  tree 
seedling  establishment  period.  Application  and 
monitoring  of  herbicides  would  be  in  accordance 
with  BLM's  FEIS  Vegetation  Management  with 
Herbicides:  Western  Oregon  1978  through  1987. 
See  the  following  Plantation  Maintenance  and 
Release  section  for  more  detail.  Alternative  7, 
which  does  not  incorporate  herbicide  use, 
employs  the  manual  method  of  paper  mulching  on 
slopes  less  than  65  percent. 

Manual  site  preparation  would  occur  on  some 
acreage  during  the  next  decade  (Table  1-2). 
Treatments  would  consist  of  paper  mulching, 
scalping  or  brush  cutting  and  piling  for  burning. 

Mechanical  site  preparation  would  consist  of 
scarification  and  piling  or  windrowing  of  slash, 
brush  and  unmerchantable  stems.  Bulldozers 
equipped  with  a  brush  blade  would  normally  be 
used.  However,  this  type  of  equipment  would  be 
restricted  to  areas  with  slopes  less  than  35 
percent,  low  soil  moisture  conditions  and  suitable 
soil  types. 


Planting 


To  achieve  adequate  reforestation  within 
five  years  following  harvest  on  timber  production 
lands,  harvested  areas  would  be  planted  with 
commercial  coniferous  species  (Douglas-fir,  grand 
fir,  incense  cedar,  Jeffrey  pine  and  ponderosa 
pine)  within  one  year  of  the  completion  of  site 
preparation.  Planting  stock  is  nursery  grown  from 
seed  collected  on  sites  and  at  elevations  similar  to 
the  specific  project  area.  Genetically  improved 
stock  is  also  being  nursery  grown  and  would  be 
scheduled  for  planting  on  15,200  acres.  The  broad 
selection  of  parent  trees  for  genetically  improved 
stock  is  intended  to  maintain  genetic  diversity 
(BLM  Instruction  Memorandum  OR  79-334). 

Reforestation  experience  in  the  Roseburg  SYUs 
shows  that  target  stocking  levels  of  245  to  320 
trees  per  acre,  depending  on  site  class,  cannot 
always  be  achieved  by  the  initial  planting.  Post- 
treatment  surveys  would  be  conducted  to 
determine  the  rate  of  survival  and  when  replanting 
or  interplanting  would  be  required  to  meet 
stocking  standards. 

Plantation  Protection 

Estimated  acreages  that  would  require  some 
type  of  protective  treatment  are  shown  in  Table  1- 
2.  Treatments  would  include  proteotion  from  the 
sun  by  shading  and  placing  plastic  tubing  or 
netting  over  seedlings  to  protect  them  from 
damage  by  deer,  elk,  porcupine  or  other  small 
animals.  Porcupine  would  be  trapped  when  they 
occur  in  significant  numbers  in  a  plantation.  The 
total  number  of  acres  requiring  each  of  these 
treatments  would  be  determined  in  conjunction 
with  normal  reforestation  surveys. 


Plantation  Maintenance  and 
Release 

Maintenance  treatments  promote  the  survival 
and  establishment  of  coniferous  seedlings. 
Release  treatments  reduce  competition  for  light, 
moisture  and  nutrients  between  shrubs  or  grass 
and  existing  commercial  coniferous  seedlings  and 
promote  dominance  and  growth  of  established 
coniferous  trees. 

In  recent  harvest  areas,  grass,  forbs,  shrubs  and 
hardwoods  often  suppress  the  growth  of  conifer 
seedlings.  The  degree  and  type  of  competition 
varies  with  the  individual  site.  On  dry  sites,  grass, 
forbs  and  shrubs  are  strong  competitors  for  water, 
while  elsewhere  hardwoods  grow  rapidly  enough 
to  shut  out  essential  light  and  compete  for  water 
during  the  dry  summer.  With  reduced  competition, 
the  conifers  rapidly  grow  beyond  the  point  where 
they  can  be  overtopped  and  further  suppressed  by 
surrounding  vegetation.  When  this  growth 
situation  is  achieved  (approximately  3  to  10  years 
from  planting),  there  would  be  no  further  control 
of  competing  vegetation  necessary. 

Each  area  proposed  for  maintenance  or  release 
treatment  would  undergo  a  site  specific 
environmental  assessment.  During  this  analysis, 
alternative  methods  of  vegetation  control  are 
considered,  including  chemical,  manual  and 
mechanical  means.  Assessments  addressing 
specific  herbicide  projects  are  prepared  and  tiered 
under  BLM's  FEIS  Vegetation  Management  with 
Herbicides:  Western  Oregon  - 1978  through  1987. 

In  recent  years,  herbicides  have  been  used 
effectively  to  inhibit  the  growth  of  competing 
vegetation,  thus  increasing  available  water, 
nutrients  and  light  for  suppressed  conifers. 
Herbicides  are  applied  aerially  or  by  several 
ground  methods.  The  method  selected  is 
dependent  on  costs,  topography,  limits  of  the 
equipment,  kind  and  dispersion  of  target  plants, 
potential  environmental  impacts  and  biological 
conditions.  Most  herbicide  applications  in  the 
Roseburg  SYUs  would  be  by  helicopters  equipped 
with  positive  shut-off  spray  systems  to  limit 
herbicide  aplication  to  the  target  areas.  Helicopter 
application  would  be  accomplished  under  contract 
through  the  competitive  bidding  process. 

Timing  of  herbicide  treatment  is  stringently 
controlled  in  relation  to  specified  weather 
conditions  such  as  temperature,  humidity  and 
wind.  There  is  full  authority  for  ordering  cessation 
of  operations  based  on  adverse  field  conditions. 
Both  equipment  and  operators  are  frequently 
checked  by  field  project  supervisors.  Only 
registered  chemicals  would  be  used  and  in 
accordance  with  labeled  instructions  on  the 
container.  Handling,  storage  and  application  of 
chemicals  would  be  in  accordance  with  the 


20 


Oregon  Forest  Practices  Act  (see  the 
Interrelationships  section,  State  and  Local 
Government). 

Protective  stream  buffers  (determined  according 
to  stream  classification  and  herbicide  used)  and 
monitoring  of  herbicide  application  are  as 
described  in  the  FEIS  mentioned  above. 
Continuous  administration  of  spraying  contracts  in 
progress  is  required.  Water  samples  of  selected 
streams  would  be  taken  prior  to  spraying  to 
establish  baseline  quality  and  at  specified  intervals 
thereafter. 

The  use  of  herbicides  for  plantation  maintenance 
and  release  is  included  in  all  alternatives  except 
for  Alternative  7  (Table  1-2).  Table  1-4  shows  the 
chemicals,  target  species  and  estimated  acreage  of 
herbicide  use  as  proposed  during  the  10-year 
period. 

Precommercial  Thinning 

Under  all  alternatives  except  Alternative  8, 
precommercial  thinning  would  be  applied  to 
timber  stands  between  10  and  20  years  of  age 
which  contain  over  500  stems  per  acre  (estimated 
to  be  60  percent  of  the  stands).  This  treatment 
concentrates  available  nutrients,  moisture  and 
light  into  those  trees  which  would  be  the  eventual 
crop  for  future  harvest. 

The  number  of  trees  cut  per  acre  during 
precommercial  thinning  is  dependent  on  the 
density  of  the  stand  before  thinning.  While  average 
spacing  is  approximately  12  feet,  the  number  of 
crop  trees  left  may  vary  between  245  and  320  per 
acre.  Contract  specifications,  emphasized  by  field 
instructions  to  crews,  cover  desired  spacing  of 
crop  trees  and  criteria  for  crop  tree  selection. 

Fertilization 

Areas  precommercially  and  commercially 
thinned  and  portions  of  areas  where  stocking 
control  was  achieved  through  plantation  spacing 
would  be  fertilized  (Table  1-2)  except  in 
Alternatives  5,  7  and  8.  Continuing  studies  and 
analysis  will  be  conducted  to  determine  fertilizer 
response  and  economic  effectiveness  of  planned 
projects.  The  average  application  is  expected  to  be 
200  pounds  of  nitrogen  per  acre.  Stands  would  be 
fertilized  when  precommercially  thinned, 
commercially  thinned  and  at  10-year  intervals 
thereafter  until  10  years  before  final  harvest.  In 
addition  to  acceleration  of  growth  for  up  to  seven 
years  following  treatment,  fertilization  reduces 
shock  associated  with  thinning. 

Comparison  of  Impacts 

This  section  compares  in  tabular  form  (Table 
1-5)  the  impacts  of  each  alternative,  including  the 
New  Preferred  Alternative  (Alt.  9)  and  the  Original 
Proposed  Action  (Alt.  4).  While  impacts  have  been 


described  in  detail  in  Chapter  3,  Table  1-5  is 
presented  to  assist  decisionmakers  and  reviewers 
by  summarizing  the  impacts  of  each  alternative, 
thereby  permitting  major  issues  to  be  defined  and 
analyzed. 

Two  areas  of  major  impacts  are  wildlife  habitat  and 
economic  conditions.  The  greatest  total  habitat 
modification  would  occur  in  Alternative  1.  The 
greatest  old  growth  habitat  modification  would 
occur  in  Alternative  5,  where  about  70  percent  of 
old  growth  habitat  would  be  removed  by  the  end  of 
the  first  decade.  Alternative  8  would  result  in  an 
increase  of  old  growth  habitat  over  the  long  term; 
all  other  alternatives  would  result  in  long-term 
decreases  of  old  growth  habitat. 

Alternative  1  would  be  most  beneficial  to  the 
economic  situation,  providing  about  1,500  more 
jobs  than  would  be  provided  by  continuation  of  the 
existing  program.  Alternative  8  would  have  the 
greatest  adverse  impact,  providing  approximately 
2,000  fewer  jobs  than  would  a  continuation  of  the 
existing  program  (Alternative  5). 


Other  areas  of  impact  are  soil  erosion  and 
sediment  yield.  Alternative  1  would  cause  the  most 
erosion;  Alternative  8  the  least.  Cumulative 
sediments  produced  as  a  result  of  timber 
management  activities  would  increase  from  levels 
in  the  past  decade  by  26  percent  in  Alternative  1 
and  decrease  by  100  percent  in  Alternative  8  where 
no  new  sedimentation  is  expected.  Alternative  8 
would  have  the  least  adverse  impacts  attributable 
to  either  soil  erosion  or  sediment  yield. 


Implementation 
Final  Decision 


After  release  of  the  final  EIS  (and 
following  the  comment  period)  the  District 
Manager  will  review  the  public  comments  on  both 
draft  and  final  EISs  and  prepare  a  Record  of 
Decision.  The  recommended  decision  may  be  to 
select  one  of  the  EIS  alternatives  intact,  or  to  blend 
features  from  several  alternatives  that  fall  within 
the  range  of  actions  analyzed  in  the  EIS.  The  final 
decision  will  be  made  by  the  State  Director. 
Significant  conflicts,  alternatives,  environmental 
preferences  and  economic  and  technical 
considerations  will  be  addressed  in  the  Record  of 
Decision,  which  is  expected  later  in  1983. 

Monitoring  and  Studies 

BLM  land  management  programs  are  monitored 
in  various  ways.  Currently,  forest  management 
practices  are  monitored  primarily  through 
administration  of  the  contracts  under  which  most 
actions  are  authorized.  Timber  sale  contracts  are 
inspected  at  least  once  a  week,  when  active,  and 
more  often  if  sensitive  operations  are  in  progress. 


21 


Table  1-5  Si 

Environmental  Components 

immary 

Units  of 

of  In 

Existing 

npac 

All.  1 

Is 

Alt.  2 

Alt.  3 

Alt.  4 

Alt.  5 

Alt.  6 

All    7 

Alt.  8 

Alt.  9 

Impacted 

Measure 

Situation 

Max.  Tbr. 

Emp.  Tbr. 

Lo  MHS 

OPA 

No 
Action 

HD 

No  Herb. 

Full  Eco. 

NPA 

Remarks 

Air  Quality 

Nitrous  oxides 

tons/year 

365 

335 

323 

314 

242 

231 

217 

109 

312 

Hydrocarbons 

tons  year 

NA 

2,279 

2,096 

2,019 

1.964 

1.512 

1,443 

1,353 

680 

1.948 

Particulates 

tons/year 

3.828 

3,521 

3,391 

3.299 

2,539 

2,425 

2.274 

1,142 

3.273 

Soils 

Lost  productivity 

acres/decade 

NA 

3.568 

3,283 

3.150 

3.072 

3.143 

2.260 

2,141 

985 

3.071 

+es  roads. 

Water  Resources 

Sediment  yield 

tons  x  100/ 

decade 

NA 

4,915 

3,151 

2,813 

2.728 

2.772 

993 

1.883 

429 

1.235 

Vegetation 

Acres  denuded 

Road  construction 

acres,  decade 

3,553 

5,568 

5.124 

4.932 

4.800 

3.696 

3.528 

3.306 

1.662 

4.764 

Plant  habitat  altered  by 

Herbicide  use 

acres-'decade 

41,231 

107,516 

98,872 

95,234 

92.653 

71,314 

68,100 

0 

32.063 

91.920 

Timber  harvesting 

acres/decade 

75.004 

74.807 

68,852 

65.956 

64.374 

73,600 

47,438 

45.107 

19,915 

61,804 

Wildlife  Habitat 

Habitat  modified 

acres  decade 

NA 

125.000 

116.200 

111,600 

109.900 

89.600 

82,300 

85.700 

21.600 

107.000 

Roads,  harvest  and  thinning. 

Early  successional 

acres 

75.000 

97.400 

92.000 

89,700 

88.100 

71.800 

73,300 

71.000 

51.600 

87  800 

Habitat  <  15  years  old 

stage  habitat,  end 

1st  decade 

Early  successional 

acres 

75,000 

134.000 

74.300 

119,500 

71,700 

72,600 

51.000 

71.100 

37,400 

100,500 

Habitat      15  years  old 

stage  habitat,  end 

10th  decade 

Old  growth  habitat, 

acres 

110,900 

66.500 

70,600 

72.400 

73.600 

35,000 

85.800 

87.600 

103,200 

74,400 

Habitat  196  years  and  older. 

end  1st  decade 

Old  growth  habitat. 

acres 

110,900 

13.700 

21.100 

31,800 

31,800 

7,300 

68.100 

70,000 

123.500 

38.900 

Habitat  196  years  and  older 

end  10th  decade 

Wildlife  Population 

Roosevelt  Elk,  end 

Percent  change 

NA 

-25% 

-25% 

-25% 

-25% 

-10% 

-5% 

-20% 

No 

-25% 

Plus  or  minus  5  percent. 

of  5th  decade, 

from  existing 

Change 

Tyee  Area  only 

Roosevelt  Elk,  end 

Percent  change 

NA 

-25% 

-25% 

-30% 

-20% 

-20% 

-5% 

-20% 

No 

-20% 

Plus  or  minus  5  percent 

of  10th  decade, 

from  existing 

Change 

Tyee  Area  only 

N.  Spotted  Owl,  end 

Pairs 

55 

0 

0 

18 

18 

0 

25 

18 

55 

19 

300  acre  old  growth 

of  10th  decade 

management  recommendation 

N  Spotted  Owl,  end 

Pairs 

55 

0 

0 

0 

0 

0 

24 

0 

42 

0 

1 .000  acre  old  growth 

of  10th  decade 

management  recommendation 

Snag  Dependent  Wildlife 

Percent  of 
Potential 

60% 

•   10% 

10% 

20-30% 

20-30% 

10% 

40-50% 

40-50% 

70-80% 

20-30% 

Long  term 

Recreation 

Ability  to 
meet  needs 

- 

-L 

♦  L 

♦  L 

♦L 

-M 

+  L 

+  L 

♦L 

+  L 

Cultural  Resources 

Inadvertent 
degradation 
(undiscovered 
sites) 

-H 

-H 

-M 

-L 

-L 

-L 

-L 

-L 

-L 

Based  on  comparison  of 
harvest  levels 

Visual  Resources 

Degradation  of 
scenic  quality 

-H 

-M 

-M 

-M 

-H 

-L 

-L 

0 

-M 

Areas  of  Critical 

Degradation  of 

_ 

-M 

0 

0 

0 

-H 

0 

0 

0 

0 

Enviromental  Concern 

resource 
values 

Special  Areas 

Site 
degradation 

- 

•H 

-L 

-L 

-L 

-H 

-L 

-L 

-L 

-L 

Energy  Use 

Billion  Btu's 

consumed 

annually 

~~ 

834 

770 

741 

723 

528 

536 

514 

218 

716 

Socioeconomic  ' 

Impacts  Compared  to 

Existing  Condition 

Total  earnings 

$  millions 

39  2 

♦21  2 

•166 

•  14  3 

+  129 

•28 

•09 

-2  4 

-21.6 

♦124 

Total  employment 

jobs 

3,225 

"1,746 

♦1,367 

+  1,178 

+  1.058 

♦  232 

-77 

-198 

-1.780 

+  1.023 

Public  revenue 

$  millions 

14  2 

-1  1 

-2.1 

-2  6 

-2  9 

-5  1 

-5.9 

-62 

-10.4 

-3  0 

Based  on  stumpage  at 
S94/M  bd   ft 

S  millions 

142 

♦22  0 

•193 

♦17.9 

•  170 

•  110 

•87 

-7  9 

-3.7 

♦  168 

Based  on  stumpage  at 
S260/Mbd  ft 

Impacts  Compared  to  No 

Action  Condition 

Total  earnings 

S  millions 

42  0 

+  184 

•138 

♦11  5 

•100 

-38 

-52 

-24.5 

♦9  6 

Total  employment 

jobs 

3  457 

•1.514 

♦1,135 

•946 

♦826 

-310 

-430 

-2,012 

+  791 

Public  revenue 

S  millions 

15.2 

-2  1 

-3  1 

-3  6 

-3  9 

-69 

-72 

-11  4 

-4  0 

Based  on  stumpage  at 
S94.'Mbd  ft 

$  millions 

15.2 

•21  0 

•183 

♦169 

♦160 

♦  7  7 

+6  9 

-4.7 

+  158 

Based  on  stumpage  at 
S260  M  bd  ft 

'  See  Chapter  3  for  discussion  of  d 

ual  impact  measures. 

r-  Beneficial 

-  Negative 

L  Low 

M  Medium         H  High 

2  Impacts  measured  f 

rom  No  Action  Condition  (Alternative  5). 

1 

^JA  -  Not  Applicable 

22 


Daily  administrative  visits  are  not  uncommon  when 
harvest  is  moving  at  a  fast  pace,  slash  disposal  is 
occurring,  or  road  construction  involving  critical 
aspects  (such  as  stream  crossing  structures)  is 
taking  place.  Service  contracts,  i.e.,  tree  planting, 
precommercial  thinning,  tubing,  manual  brush 
cutting  and  fertilization,  are  monitored  at  regular 
intervals  to  determine  the  quality  and  quantity  of 
completed  work.  Visits  to  these  operations  range 
from  twice  a  week  to  the  full-time  presence  of  a 
Bureau  contract  administrator,  depending  on  the 
experience  of  the  contractor  and  rate  of  progress. 
Daily  visits  usually  occur  when  there  is  reason  to 
believe  that  the  operator  will  require  help  in  the 
interpretation  of  contract  requirements. 

Silvicultural  treatment  success  is  monitored 
through  a  series  of  inventories  and  surveys 
performed  at  various  times  during  the  stand's  life. 
Appropriate  stocking  surveys  are  performed  both 
prior  to  and  after  a  treatment  is  accomplished. 
Information  from  these  surveys  identifies  the  need 
for  or  success  of  a  particular  silvicultural 
treatment.  This  information  is  documented  and 
maintained  in  the  operations  and  reforestation 
records  systems. 

Water  quality  monitoring  would  be  carried  out  in 
accordance  with  Executive  Orders  11514  (partially 
amended  by  1 1 991 )  and  1 2088,  Sections  208  and 
313  of  the  Clean  Water  Act  (PL  95-217,  PL  92-500 
as  amended),  BLM  Manual  7240  and  Oregon 
Department  of  Environmental  Quality 
Memorandum  of  Understanding  (MOU-OR  158). 
Standard  analytical  methods  would  be  followed. 

Monitoring  systems  for  other  resource 
management  programs  (wildlife  habitat,  visual, 
cultural  and  recreational)  outlined  in  the  final 
decision  would  be  developed  and  implemented. 

Requirements  for  Further 
Environmental  Analysis 

This  environmental  impact  statement  may  best 
be  described  as  a  regional  statement  for  the 
proposed  10-year  timber  management  plan  and  is 
considered  applicable  for  the  decade.  Site  specific 
environmental  analysis  and  documentation 
(including  categorical  exclusion  where 
appropriate)  will  be  accomplished  for  each  type  of 
treatment  under  consideration.  Interdisciplinary 
impact  analysis  will  be  tiered  within  the  framework 
of  this  and  other  applicable  environmental  impact 
statements. 

An  environmental  assessment  of  a  timber  sale  (or 
group  of  sales)  will  address  the  effects  of  the 
harvest  method,  yarding  system,  road  construction 
or  reconstruction,  slash  disposal  and  any  other 
treatments  conducted  under  the  terms  of  a  timber 
sale  contract.  Environmental  analysis  of  forest 
development  projects  such  as  precommercial 
thinning,  animal  damage  control,  fertilization  and 
herbicide  applications  will  also  be  accomplished. 


With  problems  and  conflicts  identified  through 
analysis,  it  is  possible  to  design  the  proposed 
project  in  an  environmentally  sensible  manner. 
Where  the  action  is  to  be  accomplished  by  a 
contractor,  the  environmental  assessment  is  a 
primary  means  for  determining  appropriate 
contract  stipulations.  Projects  to  be  accomplished 
by  BLM  personnel  are  conducted  in  accordance 
with  the  findings  of  the  analysis  and  decision 
documents. 

If  an  environmental  assessment  indicates  potential 
for  significant  impacts  not  already  described  in  an 
existing  EIS,  an  environmental  impact  statement  or 
a  supplement  to  an  existing  EIS  may  be  required. 

Interrelationships 

Much  of  western  Oregon  is  timber  producing 
land.  In  addition  to  the  BLM,  jurisdictions  include 
the  U.S.  Forest  Service,  State  of  Oregon,  the 
counties,  and  private  companies  and  individuals. 
Each  entity  approaches  management  of  timber 
lands  differently,  although  some  periodically 
prepare  internal  or  public  plans  for  their 
management. 


Federal  Agencies 


The  Roseburg  SYUs  share  in  part  a  common 
boundary  with  the  Umpqua  National  Forest. 
Coordination  between  the  BLM  District  Manager 
and  the  Forest  Supervisor  is  routine.  Specific 
project  and  program  coordination  takes  place  as 
needed  between  all  management  levels  of  each 
agency  and  also  between  resource  specialists.  A 
cooperative  agreement  provides  for  interagency 
road  construction  and  use  and  fire  protection. 

The  U.S.  Army  Corps  of  Engineers  has  the 
authority,  under  Section  404  of  the  Clean  Water 
Act  of  1977  (P.L.  95-217),  to  regulate  the  discharge 
of  dredged  or  fill  materials  into  any  estuary, 
wetland  or  streams  of  the  United  States  with  flow 
in  excess  of  five  cubic  feet  per  second.  Normal 
silvicultural  practices  are  exempt  from  this 
regulation.  Based  on  the  adequacy  of  BLM 
environmental  protection  practices,  the  Corps  has 
issued  BLM  a  general  permit  for  all  such  activities. 
Under  the  permit,  BLM  provides  the  Corps,  the 
State  Division  of  Lands  and  certain  environmental 
review  agencies  with  advance  notice  of  specific 
proposed  projects.  Larger  projects  exceeding 
limits  in  the  general  permit  require  a  separate 
permit. 

The  U.S.  Fish  and  Wildlife  Service  administers  the 
Endangered  Species  Act  of  1973  (as  amended). 
Accordingly,  BLM  consults  with  that  agency  when 
it  is  determined  that  a  threatened  or  endangered 
species  or  its  critical  habitat  may  be  affected.  The 
purpose  of  consultation  is  to  obtain  expert  advice 
on  the  appropriate  course  of  action.  The  outcome 
of  such  consultation  may  mean  modification  or 
abandonment  of  the  action. 


23 


The  National  Marine  Fisheries  Service  (NMFS)  is 
responsible  for  oversight  and  evaluation  of 
activities  which  may  affect  marine,  estuarine,  and 
anadromous  fishery  resources.  NMFS  participates 
in  comprehensive  land  and  water  use  planning 
under  the  terms  of  the  Water  Resources  Planning 
Act,  the  Coastal  Zone  Management  Act,  and  the 
National  Environmental  Policy  Act  and  makes 
recommendations  for  maintenance  or 
enhancement  of  anadromous  fishery  resources 
under  the  terms  of  the  Fish  and  Wildlife 
Coordination  Act. 

The  Soil  Conservation  Service  (SCS)  is 
responsible  for  all  aspects  of  the  National 
Cooperative  Soil  Survey.  Accordingly,  BLM  has  a 
cooperative  agreement  with  SCS  that  provides  for 
the  development  and  utilization  of  soil  surveys  on 
lands  that  are  of  interest  to  the  Bureau.  The  soil 
survey  data  will  provide  a  basis  for  efficient 
interpretations  for  the  Bureau  planning  and 
management  systems. 

The  National  Park  Service  (NPS)  administers  the 
Nationwide  Rivers  Inventory,  as  provided  under 
the  National  Wild  and  Scenic  Rivers  Act  of  1968. 
Present  efforts  are  directed  toward  inventory  and 
evaluation  to  determine  which  free-flowing  rivers 
and  river  segments  are  suitable  for  possible 
designation  as  components  of  the  National  Wild 
and  Scenic  Rivers  System.  BLM  consultation  with 
NPS  is  required  if  proposed  management  actions 
could  alter  a  river's  ability  to  meet  established  Wild 
and  Scenic  Rivers  Act  eligibility  and/or 
classification  criteria. 

State  and  Local  Governments 

Section  202(c)  of  the  Federal  Land  Policy 
and  Management  Act  requires  BLM  to  coordinate 
its  planning  efforts  with  those  of  State  and  local 
governments;  assist  in  resolving  inconsistencies  in 
our  mutual  planning  efforts;  provide  for  State  and 
local  governmental  involvement  in  development  of 
BLM  land  use  programs,  regulations  and  land  use 
decisions;  and  develop  BLM  resource 
management  plans  and  programs  consistent  with 
those  of  State  and  local  government  to  the  extent 
that  such  BLM  plans  and  programs  are  also 
consistent  with  Federal  law  and  regulations.  BLM 
coordination  efforts  involve  a  number  of  State  and 
local  administrative  and  planning  agencies  as 
highlighted  below. 

The  Intergovernmental  Relations  Division  for  the 
State  of  Oregon  is  the  clearinghouse  for  the 
various  State  agencies.  Notice  of  all  BLM  planning 
and  major  proposed  actions  are  provided  for 
coordinated  State  level  review  by  the  State 
Clearinghouse.  The  Regional  Councils  of 
Government  serve  as  the  clearinghouse  for 
coordinated  review  of  proposed  BLM  activities  by 
county  and  local  governments  in  their  respective 
areas  of  interest.  BLM  involvement  with  the  three 
counties  in  the  SYUs  is  largely  via  the  boards  of 


county  commissioners.  Through  these  bodies, 
county  governments  participate  in  planning  for 
land  use,  road  construction  and  recreational 
developments  on  public  lands  administered  by 
BLM. 

The  Oregon  Land  Conservation  and  Development 
Commission  (LCDC)  administers  the  state 
comprehensive  land  use  planning  program  as 
provided  in  Oregon  State  Statutes,  Chapter  197 
(ORS  197).  In  this  program,  county  and  local 
governments  are  required  to  develop 
comprehensive  land  use  plans  and  implementing 
ordinances  consistent  with  14  statewide  planning 
goals  and  guidelines.  These  call  for  a  balance 
between  conservation  and  development  to  best 
meet  public  needs. 

Close  relations  have  been  established  with  LCDC 
to  ensure  cooperation  and  coordination  of  BLM 
programs  and  planning  efforts  with  those 
conducted  by  county  and  local  governments  under 
ORS  197.  The  relationship  of  the  Roseburg 
alternatives  to  the  LCDC  Statewide  Goals  is  shown 
on  Table  1-6.  Discussion  comments  on  this  table 
generally  focus  attention  on  deficiencies  in 
addressing  the  listed  goals. 

Throughout  the  planning  process,  BLM  has 
worked  with  Douglas  County  to  achieve 
consistency  with  local  plans.  Methods  of  involving 
local  governments  have  included:  (1)  frequent 
informal  contacts  to  discuss  local  planning 
concerns;  (2)  invitations  to  participate  in  public 
tours,  workshops  and  meetings;  and  (3) 
discussions  with  the  Douglas  County  Planning 
Department  to  determine  consistency  of  BLM's 
preferred  land  use  plan  with  acknowledged  local 
plans. 

The  Comprehensive  Land  Use  Plan  for  Douglas 
County  was  adopted  by  the  Douglas  County  Board 
of  Commissioners  in  1981  and  was  recently 
accepted  by  LCDC.  To  meet  the  decision  factor 
regarding  consistency  with  State  and  local  land 
use  plans,  the  Original  Proposed  Action  and  New 
Preferred  Alternative  were  developed  to  be 
consistent  with  the  recently  adopted 
Comprehensive  Land  Use  Plan  of  Douglas  County. 


24 


Table  1-6  Relationship  of  Roseburg  EIS  Alternatives  to  LCDC  Statewide  Goals1 

LCDC  Statewide  Goal 

Number  and  Description  Discussion2 

1.  To  insure  citizen  involvement  in  all  BLM  land  use  planning  process  provides  for  public 

phases  of  the  planning  process.  input  at  every  stage  —  from  assistance  in  the  initial 

inventory  to  the  identification  of  management 
opportunities,  the  development  of  alternatives,  the 
environmental  analysis  and  the  final  decision. 


2.  To  establish  a  land  use  process  and 
policy  framework  as  a  basis  for  all 
decisions  and  actions. 


4.  To  conserve  forest  lands  for  forest 
uses. 


5.  To  conserve  open  space  and  protect 
natural  and  scenic  resources. 


6.  To  maintain  and  improve  the  quality  of 
the  air,  water  and  land  resources. 


7.  To  protect  life  and  property  from  natural 
disasters  and  hazards. 


8.  To  satisfy  the  recreational  needs  of  the 
citizens  of  the  State  and  visitors. 


9.  To  diversify  and  improve  the  economy  of 
the  State. 


12.  To  provide  and  encourage  a  safe, 
convenient  and  economic  transportation 
system. 

13.  To  conserve  energy 


All  alternatives  have  been  developed  in  accordance  with 
the  land  use  planning  process  authorized  by  the 
Federal  Land  Policy  and  Management  Act  of  1976 
which  provides  a  policy  framework  for  all  decisions  and 
actions. 

The  planning  area  is  predominately  forest  land.  All 
alternatives  provide  retention  of  inventoried  forest  lands 
for  forest  users.  No  alternative  exceeds  the  productive 
capacity  of  the  land  base  and  all  proposed  uses  are 
compatible  with  forest  uses. 

All  alternatives  conserve  open  space  and  protect 
mineral  and  cultural  resources  and  T&E  species.  All 
alternatives  except  1  protect  scenic  resources,  wildlife 
habitat,  natural  areas  and  riparian  areas  to  some 
degree. 

Only  Alternative  1  does  not  fully  address  necessary 
enhancement  of  land  and  water  quality  for  multiple  use 
of  forest  lands  or  for  meeting  Federal  and  State 
minimum  water  quality  standards.  Slash  burning  will 
increase  smoke  (see  Table  3-1).  All  alternatives  would 
comply  with  the  statewide  smoke  management  plan. 

All  alternatives  include  identification  of  potential  hazard 
areas  and  general  BLM  program  and  operational 
measures  for  protection  of  life  and  property  from 
natural  disasters  and  hazards. 

Alternative  1  emphasizes  those  activities  having 
minimal  impact  on  the  commercial  timber  base. 
Alternatives  2,  3,  4,  7  and  9  provide  a  variety  of 
developed  and  dispersed  recreation  opportunities  to 
meet  most  recreational  needs.  Alternatives  6  and  8 
provide  for  dispersed  activities,  natural  areas  and 
developed  sites  in  some  areas.  Alternative  5  would 
continue  the  existing  situation.  Alternatives  1  and  5 
would  fail  to  adequately  meet  some  increasing  needs 
for  areas  and  facilities. 

Alternatives  1  and  2  would  increase  timber  production, 
but  lack  diversity  in  that  limited  allocations  would  be 
provided  for  non-timber  values.  Alternatives  3,  4  and  9 
provide  diversity  and  increase  total  economic  returns. 
Alternative  5  maintains  status  quo  while  Alternatives  6, 
7  and  8  provide  diversity  but  result  in  decreases  in  total 
economic  returns. 

The  forest  transportation  system  will  be  expanded  and 
improved. 


Conservation  and  efficient  use  of  energy  resources  are 
objectives  in  all  BLM  activities. 

1  LCDC  goals  not  generally  applicable  to  the  proposal  and  alternatives  are:  3.  Agricultural  lands:  10.  Housing;  1 1 .  Public  Facilities  and  Services: 
14.  Urbanization;  15  Willamette  Greenway:  All  Coastal  Zone  Goals 

'  See  Chapter  3  and  Table  1-5  for  impacts  of  the  alternatives  on  the  various  resources.  Also  see  the  Index  and  Table  of  Contents  for  specific  page 
numbers  to  specific  resources. 


25 


The  Oregon  State  Forester,  by  means  of  the  Forest 
Practices  Act  of  1972,  regulates  timber  harvest 
methods  and  supportive  practices  on  all  non- 
federal lands  within  the  SYUs.  Minimum  standards 
are  prescribed  relating  to  the  following  forest 
practices: 

•  Timber  harvesting. 

•  Reforestation  of  economically  suitable  lands. 

•  Road  construction  and  maintenance  on  forest 
land. 

•  Chemical  applications. 

•  Slash  disposal. 

•  Maintenance  of  streamside  buffers. 

Although  Federal  agencies  are  not  bound  by  State 
forest  practice  rules,  Bureau  minimum  standards 
meet  or  exceed  State  rules.  The  BLM  and  USFS, 
acting  jointly,  have  entered  into  a  Memorandum  of 
Understanding  (MOU)  with  the  State  Forester  in 
this  regard. 

BLM  is  a  cooperator  in  the  Statewide  Smoke 
Management  Plan  administered  by  the  Oregon 
State  Forester  in  order  to  comply  with  the  Clean 
Air  Act  of  1963  (as  amended).  The  primary 
objective  of  the  plan  is  to  keep  smoke  from  slash 
disposal  operations  away  from  population  centers. 
Slash  burning  is  allowed  to  begin  only  when 
smoke  dispersion  conditions  are  determined  by 


Oregon  State  Department  of  Forestry  (OSDF)  to 
be  favorable. 

OSDF  is  the  primary  contractor  for  fire  protection 
of  public  lands  administered  by  BLM  in  the  SYUs. 
That  department  undertakes  presuppression  and 
suppression  actions  for  all  lands  in  the  area. 

The  Forestry  Program  for  Oregon  (Oregon  State 
Board  of  Forestry  1977)  outlines  basic  objectives 
of  the  Oregon  State  Board  of  Forestry  for  timber 
land  management  within  the  State.  The 
relationship  of  the  nine  alternatives  to  these  basic 
objectives  is  shown  in  Table  1-7.  For  the  decade 
beginning  in  1980,  BLM  harvest  projections  to 
meet  Forestry  Program  for  Oregon  targets  is  245.4 
MM  bd.  ft.  annually. 

Management  of  wildlife,  including  fish,  within  the 
SYUs  is  the  responsibility  of  the  Oregon 
Department  of  Fish  and  Wildlife.  The  Sikes  Act  (PL 
93-452)  as  amended  is  the  primary  tool  guiding 
coordination  between  BLM  and  ODFW.  BLM,  in 
managing  lands  under  its  jurisdiction,  considers 
wildlife  habitat  as  a  resource  category.  A  master 
Memorandum  of  Understanding  with  supplemental 
cooperative  agreements  describes  the  mutual 
responsibilities  of  the  two  agencies.  Oregon 
Revised  Statue  496.012  established  goals  for  the 
management  of  the  State's  wildlife.  The 


Table  1-7  Consistency  of  the  Roseburg  Alternatives  with  the  Basic 
Objectives  of  the  Forestry  Program  for  Oregon1 


ALTERNATIVES 


Basic  Objective 


Consistent 


Minimally 
Consistent 


To  maintain  the  maximum 
potential  commercial 
forest  land  base 
consistent  with  other 
resource  uses  while 
assuring  environmental 
quality 


To  maintain  or  increase 
the  allowable  annual 
harvest  level  to  its 
fullest  potential  to 
offset  potential 
socio-economic  impacts. 


To  identify  and  implement 
the  levels  of  intensive 
forest  management  required 
to  achieve  maximum  growth 
and  harvest 


To  maintain  community 
stability  by  remaining 
flexible  for  increases  in 
future  harvest  levels  that 
would  offset  proiected 
shortages 


Inconsistent 


2.3,4,6.7.8. 
9 


1 .2,3.4,5,9 


6.7.8 


1.2.3,4,6.9 


1.2,3,4,9 


5,6,7.8 


Discussion 

The  benchmark  (391.070  acres)  for  consistency 
is  the  commercial  forest  land  base  minus 
withdrawn  TPCC  lands  Environmental  quality 
would  be  protected  to  the  degree  specified  in 
the  Oregon  Forest  Practices  Act.  However. 
Alternative  1  would  not  meet  management 
guidelines  for  certain  lands  as  mandated  by 
Congressional  Acts  and  Federal  Executive 
Orders  (see  Purpose  and  Need  Section)  because 
of  impacts  on  riparian  zones. 

The  benchmark  for  consistency  is  the  current 
allowable  cut  volume  of  201  MM  bd.  ft.  per 
year  The  level  of  cutting  the  land  base  can 
sustain  is  dependent  on  number  of  acres 
allocated  to  timber  production,  level  of 
management  the  land  base  receives  and 
productivity  of  the  land 

BLM  currently  implements  a  full  range  of 
intensive  timber  management  practices  (refer 
to  Forest  Management  Treatments  and  Design 
Elements,  this  chapter)  for  optimization  of 
timber  production.  New  and  improved  practices 
would  be  implemented  consistent  with 
technological  advances 

The  benchmark  for  consistency  is  the  Roseburg 
District  cooperative  harvest  target  of  245  MM 
bd  ft..  Yr.'  as  determined  by  OSDF 


1  Arrived  at  through  consultation  with  Oregon  State  Department  of  Forestry. 

2  Oregon  State  Forestry  Department,  1980. 


26 


consistency  of  the  EIS  alternatives  with  these 
goals  is  shown  in  Table  1-8. 

The  Oregon  Department  of  Environmental  Quality 
(ODEQ)  has  lead  responsibility  for  statewide  water 
quality  management  planning  in  accordance  with 
Section  208  of  P.L.  92-500  (Federal  Water  Pollution 
Control  Act)  as  amended  by  P.L.  95-217  (Clean 
Water  Act).  BLM  and  ODEQ  have  entered  into  a 
Memorandum  of  Understanding  which  outlines 
their  respective  roles  in  meeting  State  water 
quality  objectives.  The  MOU  assures  close 
interagency  cooperation,  development  and 
implementation  of  appropriate  practices  and 
control  measures  to  comply  with  the  Clean  Water 
Act,  and  compliance  with  State  requirements.  BLM 
forest  management  practices  meet  or  exceed 
objectives  of  the  statewide  water  quality 
management  plan. 


The  cities  of  Canyonville,  Drain  and  Riddle  have 
signed  Memoranda  of  Understanding  with  the 
BLM  Roseburg  District.  These  MOUs  identify 
lands  within  municipal  watershed  boundaries  and 
describe  practices  to  be  incorporated  during 
timber  management  activities  to  maintain  water 
quality.  There  are  additional  MOUs  with  a  variety 
of  agencies  addressing  resources  within  the 
Roseburg  District. 


Table  1  -8  Consistency  of  the  Alternatives  with  State  of  Oregon  Wildlife  Goals 

Minimally 

Goal 

Consistent              Consistent              Inconsistent 

Discussion 

To  maintain  all  species  of 

1-9' 

In  the  short  term  all  alternatives  would  provide 

wildlife  at  optimum  levels 

habitat  sufficient  to  retain  a  representative 

and  prevent  the  serious 

8}                              6                      1-5.  7  and  9 

ecosystem  and  "prevent  the  serious  depletion  of 

depletion  of  any 

any  indigenous  species"    Only  Alternative  8  would 

indigenous  species 

fully  provide  optimum  long-term  levels,  although 
Alternative  6  would  provide  habitat  at  minimum 
viable  levels  for  all  species  in  the  long  term. 

To  develop  and  manage  the 

1-9' 

In  the  short  term  habitat  diversity  would 

lands  and  waters  of  the 

increase  such  that  production  and  public 

State  in  a  manner  that 

6,  8?                       2.  3,  4.  7                      1  and  5 

enjoyment  of  wildlife  would  be  enhanced  by  all 

will  enhance  the 

and  9 

alternatives    In  the  long  term  Alternatives  6  and 

production  and  public 

8  would  provide  for  all  species,  while 

enjoyment  of  wildlife 

Alternatives  2,  3,  4.  7  and  9  provide  for 
enhancement  and  enjoyment  of  wildlife,  but  not 
for  all  species  and  at  levels  below  optimum. 
Alternatives  1  and  5  would  only  enhance  early 
serai  stage  species  in  the  long  term 

To  develop  and  maintain 

1  -9.- 

All  alternatives  provide  for  public  access 

public  access  to  the  lands 

through  an  extensive  road  network  over  both  the 

and  waters  of  the  State 

short  and  long  term. 

and  the  wildlife  resources 

thereon. 

'  Short-term  (First  decade) 

2  Long-term  (Beyond  first  decade) 

27 


Chapter  2  Affected 
Environment 


m  _i 


This  chapter  addresses  the  environment  as  it 
exists  today  within  the  Roseburg  Sustained  Yield 
Units  (SYUs).  In  the  SYUs  there  are  approximately 
424,000  acres  of  BLM  managed  lands,  of  which 
404,000  acres  are  forested.  On  approximately 
169,000  acres  (40  percent),  timber  harvest  has 
occurred  for  several  decades,  and  the  environment 
described  exhibits  the  effects  of  human  use.  On 
about  255,000  acres  (60  percent),  there  has  been 
no  past  timber  management,  although 
interspersed  non-public  lands  have  been  managed 
for  timber.  Within  this  area  there  are  approximately 
111,000  acres  of  200-year-plus  old  growth  on 
scattered  tracts  of  public  land. 

Chapter  2  provides  a  basis  on  which  impacts  of  all 
the  alternatives  may  be  assessed.  Data  and 
analysis  will  be  commensurate  with  the 
importance  of  the  impact,  with  less  important 
material  summarized,  consolidated  or  simply 
referenced. 

In  preparation  of  this  chapter,  the  primary  data 
sources  are  documents  of  the  Bureau  planning 
system  developed  by  the  Roseburg  District.  The 
Unit  Resource  Analysis  (URA),  Planning  Area 
Analysis  (PAA)  and  proposed  Management 
Framework  Plan  (MFP)  for  the  Roseburg  area  are 
available  for  review  at  the  Roseburg  District  Office 
of  BLM  in  Roseburg,  Oregon. 


28 


Other  references  supplementary  to  or  updating 
planning  system  data  are  cited  within  the  body  of 
the  text  by  author  and  date  of  publication.  A  listing 
of  these  references  appears  in  the  References 
Cited. 

Climate  and  Air  Quality 

The  area  has  a  temperate  marine  climate  with 
warm  summers  and  mild,  wet  winters.  In 
Roseburg,  the  mean  maximum  temperature  is 
84°  F,  the  mean  minimum  is  33°  F.  The  record 
high  was  109°  F  in  1946  and  the  record  low  was 
-6°  in  1888.  During  summer  days,  soil 
temperatures  have  been  found  to  exceed  160°  F. 
Monthly  precipitation,  mostly  as  rain,  ranges  from 
5.46  inches  in  Riddle  and  8.89  inches  in  Reston 
during  January  to  less  than  0.3  inches  during  July. 
Average  precipitation  is  about  45  inches  annually 
in  the  Roseburg  SYUs.  The  maximum  recorded 
was  60  inches  at  Twelvemile  Creek.  Snow  may 
block  roads  in  some  winters,  but  snow  is  generally 
short-lived. 

Air  movement  patterns  are  predominately  from  the 
north  (U.S.  Department  of  Commerce,  Weather 
Bureau,  Cited  in  USDI,  BLM  1980a),  except  during 
the  late  fall  and  early  winter  months  (November, 
December,  January),  when  winds  are  southerly. 
Mean  yearly  wind  speeds  in  Roseburg  are  4.5 
miles  per  hour. 

During  the  late  summer  and  fall  months,  the 
valleys  and  interior  hills  of  Douglas  County  are 
subject  to  frequent  night-time  inversions—cool  air 
stabilizing  below  warmer  air  above.  Specific 
information  on  the  extent  and  duration  of  these 
conditions  within  the  area  is  not  available. 


Under  the  Clean  Air  Act  Amendments  of  1970, 
Oregon  has  been  divided  into  five  Federal  Air 
Quality  Control  Regions  (AQCRs)  on  the  basis  of 
pollution  concentrations,  geography  and 
economics.  The  EIS  area  is  in  the  southwest 
Oregon  AQCR.  Air  quality  in  this  area  is  good  and 
meets  all  air  quality  standards  (ODEQ  1981 ). 

Provisions  of  the  Clean  Air  Act  Amendments  of 
1977  were  made  to  ensure  that  areas  with  clean  air 
do  not  suffer  deteriorating  air  quality.  Mandatory 
Class  I  areas  are  Crater  Lake  National  Park  and 
Diamond  Peak,  Kalmiopsis,  Mt.  Washington,  Three 
Sisters,  and  Mt.  Jefferson  Wilderness  areas.  The 
SYUs  and  surrounding  areas  are  designated  Class 
II,  which  allows  only  moderate  deterioration  of  air 
quality. 

The  only  sampling  site  within  the  EIS  area  is 
located  in  Roseburg.  Since  1971,  total  suspended 
particulate  levels  have  exceeded  secondary 
Federal  health  standards  (more  than  150 
micrograms  per  cubic  meter  (ug/m3))  14  times  and 
have  once  violated  primary  standards  (more  than 
260  ug/m3)  (ODEQ  1981).  The  annual  geometric 
mean  for  total  suspended  particulates  has  ranged 
from  64.7  micrograms  per  cubic  meter  (ug/m3)  in 
1974  to  46.0  ug/m3  in  1980  (ODEQ  1981).  See 
Table  2-1. 

Occasionally,  smoke  from  slash  burning  in  the 
SYUs  has  been  visible  in  the  population  centers  of 
Roseburg  and  Eugene-Springfield  (ODEQ  1981). 
Slash  smoke  problems  (visible  smoke)  in  Douglas 
County  are  shown  in  Table  2-2. 


Table  2-1  Total  Suspended  Particulates  in  Roseburg 

(mic 

rograms  per  cu 

bic 

meter, 

ug/m 

3) 

Days 

Exceeding 

Annual 

No.  of 

Standards 

Geometric 

24  Hour 

Averages 

Year 

Samples 

150 

2601 

Mean 

Maximum 

2nd  Highest 

1971 

98 

2 

0 

51.2 

185 

180 

1972 

88 

2 

0 

59.3 

222 

162 

1973 

58 

4 

0 

52.9 

233 

181 

1974 

57 

4 

1 

64.7 

263 

258 

1975 

52 

0 

0 

43.9 

93 

89 

1976 

51 

0 

0 

47.8 

140 

121 

1977 

60 

1 

0 

52.0 

170 

170 

1978 

60 

0 

0 

51.4 

104 

103 

1979 

32 

0 

0 

- 

109 

92 

1980 

60 

1 

0 

46.0 

157 

137 

'Secondary  standard  =  >150  ug/m 

';  primary  standard  =     -260  i 

jg/m3. 

Source: 

ODEQ  1981 

29 


Table  2-2  Slash  Smoke  Problems 

in  Douglas  County 

Year 

No.  of  Burns 

Acres 

Tons  of  Slash 

Number  of  Problems 

Total                BLM          Days 

1976 

1977 
1978 
1979 
1980 
1981 

630 
601 
641 
603 
690 
141 

24,986 
21,542 
25,617 
24,103 
26,507 
3,742 

686,523 
888,965 
1,042,245 
909,172 
756,713 
51,457 

14 
4 
9 
0 

29 
0 

1 
0 

5 

0 

12 

0 

1 

0 
3 
0 
1 
0 

Source: 

ODEQ  1981; 

OSDF  Annual  Reports 

of  Oregon  Smoke  Ma 

nagement  Plans,  1977  thi 

-ough  1982. 

Geology  and  Topography 

The  SYUs  are  located  within  the  Coast  Range, 
the  Klamath  Mountain  and  the  Western  Cascades 
physiographic  provinces  (Figure  2-1).  The  Coast 
Range  is  made  up  of  submarine  basalts  and 
marine  sediments  of  the  Tyee  and  Umpqua 
Formations.  The  Klamath  Mountain  province  is 
geologically  complex,  consisting  of  marine 
sediments,  plutonic  and  volcanic  rocks  that  have 
been  folded,  faulted  and  metamorphosed.  The 
topography  is  rugged  due  to  the  resistant  type  of 
rock  found  there.  Serpentine  is  fairly  widespread 
in  the  Klamath  Mountains,  and  extends 
northeasterly  from  the  Cow  Creek  area  through 
the  central  and  southern  part  of  the  SYUs.  Granite 
and  diorite  bedrock  are  found  in  several  large 
areas  in  the  southeastern  part  of  the  SYUs.  These 
erode  easily,  creating  steep,  short  sideslopes  and 
sharp  ridges. 

Also  found  in  the  Klamath  Mountain  province  are 
thickly  bedded  sandstone  and  thin  interbeds  of 
mudstone,  volcanic  rock  sometimes  called 
greenstone  because  of  the  abundance  of  chlorite, 
and  a  chert  pebble  conglomerate  overlain  by 
sandstone,  siltstone  and  conglomerate.  The 
Western  Cascade  Province  is  characterized  by  a 
rugged  topography  with  irregular  ridges  and  deep 
narrow  valleys.  The  rocks  are  mostly  volcanics. 
Intrusive  rock  bodies  in  the  Western  Cascades  are 
generally  small  and  consist  of  plugs,  dikes,  sills 
and  domes. 

Throughout  the  SYUs,  slopes  range  from  0  percent 
to  vertical  and  average  about  60  percent.  Over  40 
percent  of  the  area  has  slopes  in  excess  of  65 
percent.  Elevations  range  from  150  feet  at  Elkton, 
500  feet  at  Roseburg  and  650  feet  at  Myrtle  Creek 
to  2,800  feet  at  Baughman  Lookout,  3,900  feet  at 
Dutchman  Butte,  4,400  feet  at  Deadman  Mountain 
and  4,800  feet  at  Huckleberry  Mountain. 

Soils 

The  "Soils  of  the  Roseburg  District"  (Wert 

et  al.  1977)  describes  the  soils  resource  of  the  EIS 

area  in  detail.  A  generalized  soils  map,  which 


contains  14  broad  groupings  of  soils,  is  shown  as 
Figure  2-2.  This  map  is  useful  only  to  show  a 
general  view  of  the  major  soils  in  the  Roseburg 
SYUs.  Soil  moisture  and  soil  temperature  directly 
influence  the  ability  of  the  soil  to  support  plant  life. 

Soils  within  the  SYUs  are  generally  capable  of 
producing  abundant  plant  growth.  Most  soils  have 
a  high  content  of  organic  matter,  moderate  to  high 
nutrient  levels  and  medium  bulk  densities  (1.1  to 
1.3  gm/cm3).  Soils  at  high  elevations,  however,  are 
often  low  in  organic  matter  and  nitrogen. 

Dry  ravelling  of  soil  materials,  landslides  and  soil 
surface  erosion  occur  naturally  throughout  the 
Roseburg  SYUs.  Total  soil  loss  from  these  factors 
in  the  undisturbed  forests  is  estimated  to  be  0.15 
to  0.40  tons  per  acre  per  year  (t/ac/yr).  Soil  loss 
and  loss  of  soil  productivity  have  accelerated  as  a 
result  of  timber  harvesting  and  road  building. 
District  experience  has  shown  that  in  areas  where 
road  construction  and  harvests  have  taken  place 
and  regrowth  is  now  established,  soil  loss  is  about 
1  to  3  t/ac/yr.  In  typical  areas  where  tractor 
logging  and  downhill  yarding  have  been  practiced, 
erosion  is  estimated  to  be  230  t/ac/yr  initially, 
reducing  to  an  estimated  5  to  10  t/ac/yr  after  three 
to  five  years,  finally  stabilizing  at  an  estimated  1  to 
3  t/ac/yr  in  about  two  decades.  During  the  past 
decade  soil  productivity  has  been  reduced  on 
9,279  acres  of  BLM-administered  land  (5,276  acres 
by  harvest  and  yarding  methods  that  compact  the 
soil  and  3,553  acres  bared  by  road  construction 
activities).  Table  2-3  shows  totals  within  the 
Roseburg  District. 

Fragile  soils  are  found  throughout  the  Roseburg 
SYUs.  These  soils  include  33,547  acres  of  granitic 
soils  or  other  soils  that  have  a  high  potential  for 
mass-failure  and  138,711  acres  of  soils  on  very 
steep  slopes  with  inclusion  of  unstable  headwalls. 
These  acres  and  the  percentages  of  the  BLM  area 
are  shown  in  Table  2-4. 

Mass  movements  tend  to  occur  in  draws  where  the 
slopes  are  steep  and  the  soils  are  extremely 
fragile.  Fragile  soils  are  mostly  shallow  (less  than 
20  inches  to  bedrock),  have  greater  than  35 


30 


percent  by  volume  of  coarse  fragments  (rock  and 
gravel),  occur  on  slopes  of  60  to  80  percent  or 
greater  and  have  low  water-holding  capacity  and 
moderately  rapid  permeability. 

The  two  major  kinds  of  mass  movement  of  soils  in 
the  Roseburg  SYUs  are  slumps  and  debris 
avalanches.  Slumps  are  one  or  more  blocks  of  soil 
that  have  rotated  out  of  a  hillside  along  a  bowl- 
shaped  failure  plane.  Debris  avalanches  are  the 
rapid  movement  of  incoherent  soil,  rocks  and 
forest  debris  down  steep  draws.  Soils  that  are 
associated  with  debris  avalanches  are  usually 
those  loamy  and/or  gravelly  soils  formed  over 
decomposing  granitic  bedrock,  sandstone,  hard 
tuffs  or  breccias  on  70  percent  or  greater  slopes. 
Debris  avalanches  occur  on  the  following  soils  in 
the  SYUs:  Holland  and  Siskiyou  (slopes  over  70 
percent);  Digger,  Jason  and  Umpcoos  (over  75 
percent  slopes);  Larmine,  Atring,  Kilchis, 
Harrington,  Chamate  and  Shippa  soils  (slopes  over 
80  percent). 


Table  2-3  Bared  Soils  and  Road 
Surfaces 

Failing  cut-and-fill  slopes  and  soil 
mass-movements  700  acres 

Unsurfaced  roads  causing  erosion      600  acres 

Road  surface  12,000  acres 

Totals  13,300  acres 


Footnote 

Estimates  based  on  district  soil  scientist  field  experience  and 

observations 


Water  Resources 

The  SYUs  lie  within  four  major  river  basins. 
There  are  188,440  acres  of  BLM-administered  land 
drained  via  the  South  Umpqua  River,  65,100  acres 
drained  via  the  North  Umpqua  River,  another 
154,900  acres  are  drained  by  the  main  stem  of  the 
Umpqua  River  and  14,560  acres  are  drained  by  the 
Middle  Fork  Coquille  River.  Within  these  large 
watersheds,  smaller  sub-watersheds  have 
problems  with  debris,  sedimentation,  bank  erosion 
and  elevated  temperatures.  The  rivers  and  creeks 
with  severe  problems  are  shown  in  Table  2-5. 
Water  quality  problems  in  the  SYUs  are  non-point 
source  pollution  resulting  from  debris, 
sedimentation,  bank  erosion  and  elevated 
temperatures.  High  sediment  loads  and 
streambank  erosion  occur  during  periods  of  peak 
flow  (winter  and  spring),  while  problems  of 
elevated  temperatures,  low  dissolved  oxygen  and 
nuisance  algae  occur  during  periods  of  low  flow 
(summer).  Streamflow  data  collected  at  gauging 
stations  within  or  nearby  the  SYUs  are  given  in 
Table  2-6,  Streamflow  Data. 

Table  2-7  shows  water  and  sediment  discharge 
measured  at  selected  gauging  stations  throughout 
the  SYUs.  The  sediment  yield  ranges  from  0.4  tons 
per  acre  at  Olalla  Creek  near  Tenmile  to  3.0  tons 
per  acre  at  the  mouth  of  Lookingglass  Creek. 
These  values  represent  a  long-term  average  and 
may  differ  greatly  from  year  to  year.  Peak  yields 
occur  during  the  period  of  high  runoff. 

Sediment  losses  from  the  SYUs  depend  on  the 
changing  combination  of  many  watershed 
variables.  Within  the  SYUs,  which  are  mostly 
forested,  a  small  portion  of  the  sediment  produced 
is  attributable  to  purely  natural  forces.  This  loss 
represents  the  geologic  rate  of  erosion. 


Table  2-4  Fragile  and  Problem  Soils 

Problem 

Figure  2-2 
Color 

Acres 

Percent 
of  SYUs 

Soils  on  very  steep  slopes  with  inclusion  of  unstable 
headwalls. 

Blue 

138,711 

33 

Soils  on  very  steep  slopes  with  inclusion  of  unstable 
headwalls  and  a  high  potential  for  failure  when  trees  are 
removed. 

Green 

4,639 

1 

Granitic  soils  with  severe  surface  erosion  and  inclusion 
of  unstable  headwalls. 

Yellow 

24,481 

6 

Granitic  soils  on  very  steep  slopes  with  inclusion  of 
unstable  headwall  and  a  high  potential  for  failure  when 
trees  are  removed. 

Green 

4,426 

1 

Footnote 

Due  to  map  scale  (Fig.  2-2)  it  is  not  possible  to  delineate  individual  fragile  sites 

I 


Lookout  Poirrr 

4-X 


WILLAMETTE 


iv'T^ 


> 


11 


\W 


Bu/nl  Pea*   * 

Li 


FIGURE  21 
PHYSIOGRAPHIC    PROVINCES 


U.  S  DEPARTMENT  OF  THE  INTERIOR 

BUREAU  OF  LAND  MANAGEMENT 

ROSEBURC  DISTRICT 

DOUGLAS  AND  SOUTH  UMPQUA 
SUSTAINED  YIELD  UNITS 

Roseburg  Environmental  Impact  Statement  Area 

1982 


UDICMESIC     SOILS 

1  Digger- Jason- Preacher  Association 

2  Honey  grove-Peavine-Preacher  Association 

3  Honeygrove-Shtvigny  Association 

4  Klickitat-Harrington  Association 


FIGURE    2-2 
GENERAL  SOILS 


U.  S.  DEPARTMENT  OF  THE  INTERIOR 

BUREAU  OF  LAND  MANAGEMENT 

ROSEBURG  DISTRICT 

DOUGLAS  AND  SOUTH  UMPQUA 
SUSTAINED  YIELD  UNITS 

Roseburg  Environmental  Impact  Statement  Area 

1982 


35 


Table  2-5  Severe  Water  Quality  Problems 

Water 

Elevated 

Withdrawals 

Severe 

Water 

Causing 

Sedimen- 

Streambank 

Temper- 

Quality 

tation 

Erosion 

atures 

Problems 

Cow  Creek 

X 

X 

X 

North  Myrtle  Creek 

X 

X 

X 

X 

South  Myrtle  Creek 

X 

X 

X 

X 

South  Umpqua  River 

X 

X 

X 

X 

Twelvemile  Creek 

X 

Elk  Creek 

X 

X 

X 

Smith  River  (Headwater) 

X 

X 

X 

Tenmile  Creek 

X 

X 

X 

Lookingglass  Creek 

X 

X 

X 

Olalla  " 

X 

X 

X 

Middle  Fork  Coquille  River 

X 

X 

Sutherlin  Creek 

X 

X 

Rock  Creek 

X 

X 

X 

Canton  Creek 

X 

X 

Canyon  Creek 

X 

X 

X 

Days  Creek 

X 

X 

X 

Little  River 

X 

X 

Source:  ODEQ  Aug.  1978 

Groundwater  supplies  are  highly  variable  and 
limited.  Most  wells  produce  only  enough  water  to 
supply  single  households,  and  some  may  go  dry 
during  the  summer.  In  the  Drain-Yoncalla  area, 
water  supply  is  very  poor.  In  the  Willis  and  Rice 
Creek  Drainages,  groundwater  supply  is  almost 
non-existent.  Cow  Creek  has  one  of  the  better 
groundwater  supplies  in  the  county.  Winston, 
Dillard,  Tenmile,  Elkton  and  Olalla  have  fair 
supplies. 

Heavy  irrigation  withdrawals  are  taken  from  Elk 
Creek,  Calapooya  Creek  and  the  Umpqua  River 
and  throughout  the  South  Umpqua  River  system. 
Bear  Creek  and  Adams  Creek  watersheds,  located 
near  Drain  and  Yoncalla,  are  used  as  sources  for 
domestic  water  supply  by  these  two  communities. 
In  addition,  several  communities  withdraw  water 
for  domestic  use.  The  Roberts  Creek  Water  District 
has  rights  on  the  South  Umpqua  River,  the  South 
Umpqua  Water  Association  has  rights  on  Cow 
Creek  and  serves  40  percent  of  Canyonville  and 
the  area  between  Riddle  and  Canyonville.  The 
remainder  of  Canyonville  uses  O'Shea  Creek  and 
West  Fork  of  Canyon  Creek.  Myrtle  Creek  uses  the 
South  Umpqua  River  as  a  backup  source,  and  the 
Tri-City  Water  Association  has  rights  on  the  South 
Umpqua.  Riddle  uses  Judd,  Cow  and  Russell 
Creek  watersheds  for  municipal  water  supplies. 


Vegetation 


The  SYUs  are  located  in  the  Northwest 
Coastal  Coniferous  Sub-biome,  which  is  the  most 
densely  forested  region  in  the  Coniferous  Biome. 
Characterized  by  easy  regeneration  and  rapid 
growth,  it  produces  trees  of  impressive  sizes.  The 
lower  vegetative  layers  are  usually  poorly 
developed  except  where  open  canopies  encourage 
a  lush  understory  of  grasses,  shrubs  and 
herbaceous  species.  Additional  information  may 
be  found  in  the  BLM  Timber  Management  FEIS. 

Terrestrial  Vegetation 

For  purposes  of  this  EIS,  vegetation  is 
generally  described  in  terms  of  "zones"  adapted 
from  those  identified  by  Franklin  and  Dyrness  in 
Natural  Vegetation  of  Oregon  and  Washington 
(1973).  A  detailed  description  of  each  zone  and 
plant  community  listed  below  may  be  found  in  that 
source  or  from  data  prepared  in  the  Roseburg 
District.  A  complete  list  of  common  and  scientific 
names  for  all  plants  discussed  is  available  upon 
request. 

Portions  of  three  major  vegetative  zones,  Mixed 
Conifer,  Western  Hemlock  and  Interior  Valley,  are 
found  within  the  SYUs. 

The  southern  portion  of  the  SYUs  above  1,000  feet 
in  elevation  is  generally  occupied  by  the  Mixed 
Conifer  Zone.  Approximately  50  percent  of  BLM- 
administered  lands  in  the  SYUs  lie  within  one  of 
the  following  three  major  plant  communities. 


36 


Table  2-6  Streamflow  Data 

Location 

Average  Discharge/Yr 

(CFS)               (Ac.  Ft.) 

Peak 

(CFS) 

Discharge 

(Date) 

Minimum 

(CFS) 

Discharge 

(Date) 

Cow  Creek 
(Riddle) 

898 

650,600 

41,100 

Oct.  1950 

7.4 

Aug.  1977 

Olalla  Creek 
(Tenmile) 

94.2 

68,200 

12.300 

Dec.  1955 

0 

several  yrs. 

Tenmile  Cr. 
(Tenmile) 

64.4 

46,700 

3,650 

Jan. 1971 

0 

several  yrs. 

Lookingglass 
Cr.  (Brockway) 

287 

207,900 

35.000 

Dec.  1955 

0 

several  yrs. 

Steamboat  Cr. 
(below  Canton 

Cr.) 

741 

536,900 

51,000 

Dec.  1964 

30 

Sept.  1973 

Rock  Cr.  (above 
fish  hatchery) 

373 

270,200 

22,800 

Dec.  1964 

14 

Sept.  1966 

Little  River 
(Peel) 

475 

344,100 

22,700 

Nov.  1953 

14 

several  yrs. 

N.  Umpqua  R. 
(Winchester) 

3,746 

2,714,000 

150,000 

Dec.  1964 

383 

Sept.  1960 

Calapooya  Cr. 
(Oakland) 

485 

351,300 

26,600 

Nov.  1961 

0 

1966,  1974 

Umpqua  River 
(Elkton) 

7,504 

5,437,000 

265.000 

Dec.  1964 

640 

July  1926 

Elk  Creek 

(Drain) 

227 

164,400 

15,000 

Feb.  1961 

0 

several  yrs. 

Smith  River 
(Gardiner) 

976 

547,700 

26,000 

Feb.  1961 

4.3 

Aug.  1966 

S.  Umpqua  R. 
(Tiller) 

1,042 

754,900 

60,200 

Dec.  1964 

20 

Sept.  1911 

Elk  Creek 
(Drew) 

85.6 

62,020 

8,880 

Dec.  1964 

0 

1974,  1977 

Days  Creek 
(Days  Creek) 

44.4 

32,170 

3,450 

Feb.  1956 

0 

Jl/Ag  1961 

S.  Myrtle  Cr. 
(Myrtle  Cr.) 

65.9 

57,740 

3,050 

Dec.  1956 

0.2 

Aug.  1961 

N.  Myrtle  Cr. 
(Myrtle  Cr.) 

74.2 

53,760 

3,260 

Jan.  1964 

0 

1973,  1977 

S.  Umpqua  R. 
(Brockway) 

2,899 

2,100,000 

125,000 

Dec.  1964 

16 

Aug.  1977 

Source:  USDI.  BLM  Roseburg 

District  URA  1980a  (as  of  1978  water  year) 

37 


Table  2-7  Sediment  Discharge  Data 

Location 

Mean  Annual 
Suspended  Sediment  Discharge 

Maximum 

Observed 

Discharge 
(Tons/Year) 

Concentration 
(Mg/L) 

Yield 
(Tons/ Ac) 

Concentration 
(Mg/L) 

Discharge 
(Tons/Day) 

Steamboat  Cr. 
(below  Canton  Cr.) 

210,000 

240 

1.2 

3,870 

106,000 

N.Umpqua  R. 
(Winchester) 

800,000 

120 

1.0 

768 

71,200 

Umpqua  River 
(Elkton) 

3,500,000 

370 

1.5 

927 

196,000 

Elk  Creek 
(Drain) 

74,000 

230 

1.1 

2,930 

9,730 

Olalla  Creek 
(Tenmile) 

16,000 

150 

0.4 

3,600 

3,040 

Lookingglass 
Cr.  (Brockway) 

310,000 

890 

3.0 

2,600 

35,100 

S.  Umpqua  R. 
(Brockway) 

1,700,000 

500 

1.6 

1,800 

208,000 

S.  Umpqua  R. 
(Tiller) 

140,000 

120 

0.5 

1,260 

65.100 

Cow  Creek 
(Riddle) 

370,000 

370 

1.3 

1,360 

64,600 

Source:  USDI,  BLM  1980a. 

a.  White  fir,  western  hemlock,  vine  maple,  western 
yew 

b.  White  fir,  Douglas-fir,  Whipple  vine 

c.  Douglas-fir,  incense  cedar,  pine-mat  manzanita. 

Frequent  associates  to  these  plant  communities 
which  are  also  important  to  the  forest  industry 
include  sugar  pine,  ponderosa  pine,  western 
redcedar  and  western  white  pine. 

The  Western  Hemlock  Zone  extending  throughout 
the  northern  portion  of  the  SYUs  at  all  elevations, 
covers  approximately  47  percent  of  BLM- 
administered  lands  in  the  EIS  area.  It  is  famous  for 
its  subclimax  species,  Douglas-fir,  which  is  often 
the  sole  dominant  tree  in  the  forest.  As  a  pioneer 
species,  Douglas-fir  normally  constitutes  a  serai 
(successional)  stage  during  the  vegetative 
community  development  process.  This  zone 
encompasses  six  major  plant  communities  with 
various  associations  of  trees,  shrubs  and  forbs 
relative  to  specific  climatic  conditions  such  as 
aspect,  moisture,  soil  type  and  depth,  etc.  These 
communities  are  listed  on  a  site  moisture  gradient 
from  dry  to  wet: 


a.  Douglas-fir,  ocean  spray 

b.  Western  hemlock,  golden  chinkapin 

c.  Western  hemlock,  Pacific  rhododendron,  salal 

d.  Western  hemlock,  Pacific  rhododendron, 
Oregon  grape 

e.  Western  hemlock,  swordfern,  Oregon  oxalis 

f.  Western  redcedar,  western  maidenhair  fern, 
ladyfern 

The  Interior  Valley  Zone  includes  the  lowlands  and 
valley  bottoms  enclosed  by  the  Cascade'and  Coast 
Ranges.  Approximately  3  percent  of  BLM- 
administered  lands  occur  within  this  zone  at 
elevations  up  to  1,300  feet.  Plant  communities  vary 
from  grasslands  and  oak-madrone  woodlands  in 
low  areas  to  conifer  forests  on  the  slopes. 
Frequent  associates  to  these  plant  communities 
are  Douglas-fir,  ponderosa  pine,  incense  cedar, 
ocean  spray,  Oregon  grape  and  rye  grasses. 

Riparian  habitat  occupies  the  transitional 
terrestrial  areas  from  the  water's  edge  to  the 
better-drained  slopes.  Vegetation  in  these  areas 
ranges  from  a  few  aquatic  species  and  the 
hardwood-western  redcedar-hemlock  type,  to  the 
predominant  Douglas-fir  stand  usually  found  on 
the  slopes. 


38 


Habitat  stratification  for  all  forested  land  of  the 
entire  Roseburg  Area  is  depicted  in  Table  2-8.  The 
entire  Roseburg  Area  includes  all  lands  in  Douglas 
County  east  of  the  crest  of  the  coast  range. 
Acreages  listed  are  a  composite  of  all  ownerships 
obtained  from  several  sources  (USFS;  OSDF; 
OSDT)  as  well  as  the  BLM  forest  inventory.  The 
acreages  of  BLM-administered  lands  are  shown  for 
comparison. 


Table  2-8  Existing  Forest  Habitat 
Stratification  of  Entire  Roseburg 
Area  (Acres) 

Habitat  Age 

BLM 

All  Lands 

Grass/Forb 
(non-stocked  and 
0-7  years) 

34,100 

213,900 

Brush/Seedling 
(8-15  years) 

40,900 

239,100 

Pole/Sapling 
(16-45  years) 

56,400 

356,800 

Young  2nd  Growth 
(46-115  years) 

82,200 

258,900 

Mature 
(116-195  years) 

79,800 

121,500 

Old  Growth 
(196+  years) 

110,900 

234,100 

Source:  USDI.  BLM;  USDA,  FS;  Oregon  State  Department  of 
Forestry;  Oregon  State  Department  of  Transportation  (Parks  and 
Recreation  Branch) 

The  old-growth  forests  existing  today  are  complex 
ecosystems  which  have  evolved  by  natural 
selection  through  successional  stages  during  the 
vegetative  community  development  process. 
Evidence  now  points  to  the  simultaneous  evolution 
of  mycorrhizal  tree  hosts,  hypogeous  fungi,  and 
small  mammals  that  function  as  a  transport 
mechanism  for  the  fungi. 

Research  required  to  fully  understand  the 
relationships  and  importance  of  these  processes  to 
long-range  timber  production  has  not  yet  been 
completed.  It  now  appears  that  dispersal  of 
mycorrhizal  fungi  by  small  mammals  may  be  a 
critical  factor  in  forest  plantation  establishment 
and  survival  in  some  instances  (Maser  et  al.  1978). 
The  functioning  of  the  old  growth  forest  as  a 
system,  however,  has  not  yet  been  studied  in 
depth.  As  recently  as  10  years  ago,  nothing  was 
known  about  sources  of  nitrogen  in  old  growth 
stands.  It  is  now  known  that  lichens  which  inhabit 
the  canopy  of  live  old  growth  trees  fix  significant 
amounts  of  nitrogen  which  ultimately  become 


available  to  the  whole  forest  through  leaching, 
litter  fall  and  decomposition.  Also,  lichens  and 
wood-dwelling  bacteria  on  standing  dead  trees 
and  logs  have  recently  been  identified  as 
significant  sites  of  nitrogen  fixation  (Franklin  et  al. 
1981). 

Seed  zones  are  accepted  as  generally 
encompassing  a  geographic  area  within  which  the 
factors  affecting  reforestation  and  subsequent 
growth  are  relatively  homogeneous  (Appendix  A). 
Seed  zones  and  elevational  intervals  involving 
BLM-administered  lands  in  the  Roseburg  SYUs  are 
shown  in  Table  A-1. 

Wetland  and  Aquatic 
Vegetation 

Wetlands  are  those  areas  inundated  by 
surface  or  ground  water  at  a  frequency  sufficient 
to  produce  a  saturated  or  seasonally  saturated  soil 
condition.  Examples  of  wetlands  include  marshes, 
swamps,  bogs,  wet  meadows  and  natural  ponds. 
Sedges,  grasses,  rushes,  skunk  cabbage,  cattails 
and  algae  are  typical  wetland  and  aquatic  plants. 

Sensitive,  Threatened  and 
Endangered  Plants 

Endangered  plants  are  those  species  that  are 
in  danger  of  extinction  throughout  all  or  a 
significant  portion  of  their  range.  Threatened  plant 
species  are  those  that  presently  are  not 
endangered  but  are  likely  to  become  so  within  the 
foreseeable  future  throughout  all  or  a  significant 
portion  of  their  range.  Sensitive  plants  are  those 
species  not  yet  officially  listed  but  undergoing  a 
status  review  (see  Glossary-Sensitive  Species). 

Botanical  surveys  for  sensitive,  threatened  and 
endangered  plants  were  conducted  on  the 
Roseburg  District  from  1978  through  1980  and  are 
continuing.  At  present,  one  federally  listed 
endangered  plant  (Arabis  macdonaldiana, 
McDonald's  arabis)  is  suspected  to  occur  in  the 
EIS  area,  but  as  yet  remains  unobserved.  Several 
species  observed  in  the  EIS  area  are  currently 
under  review  for  listing  as  threatened  or 
endangered  by  the  U.S.  Fish  and  Wildlife  Service 
(Table  2-9).  The  final  status  of  these  species  will 
be  determined  as  sufficient  data  are  collected. 


39 


Table  2-9  Sensitive  Species  Currently  Under  Review  For  Possible  Listing 

Candidate 

Observa- 

Scientific Name 

Common  Name 

for1 

tions2 

Arabis  koehleri 

shrubby  rockcress 

E 

B 

var.  koehleri 

Aster  vialis 

wayside  aster 

E 

C 

Calochortus  greenei 

Green's  mariposa-lily 

T 

B 

Calochortus  howellii 

Howell's  mariposa-lily 

T 

B 

Camassia  leichtlinii 

great  camas 

A 

var.  leichtlinii 

Cypripedium  californicum 

California  lady's  slipper 

T 

B 

Cypripedium  montanum 

mountain  lady's  slipper 

T 

A 

Darlingtonia  californica 

California  pitcherplant 

T 

C 

Dicentra  formosa 

Oregon  dicentra 

E 

C 

(spp.  oregana) 

Frasera  umpquaensis 

Umpqua  swertia 

T 

C 

Kalmiopsis  leachiana 

kalmiopsis 

C 

Lathyrus  holochlorus 

thin-leaved  peavine 

T 

B 

Lewisia  cotyledon 

imperial  lewisia 

T 

B 

var.  howellii 

Limnanthes  gracilis 

slender  meadow-foam 

T 

B 

var.  gracilis 

Mimulus  pygmaeus 

pygmy  monkey  flower 

C 

Perideridia  erythrorhiza 

false  caraway 

T 

B 

Phacelia  capitata 

scorpion  weed 

T 

A,B 

Phacelia  verna 

Umpqua  phacelia 

T 

A,B 

Plagiobothrys  hirtus 

rough  allocarya 

C 

fspp.  hirtus) 

Romanzoffia  thompsonii 

romanzoffia 

T 

A 

Sidalcea  cusickii 

Cusick's  checker-mallow 

T 

B 

Synthyris  missurica 

Howell's  grouse  flower 

C 

(spp.  hirsuta) 

Thlaspi  montanum 

pennycress 

T 

A,B 

var.  siskiyouensis 

Viola  lanceolata 

western  bog  violet 

T 

C 

var.  occidentalis 

'  Threatened  (T).  endangered  (E),  undesignated  to  date  (blank).  All  species  are  designated  as 

Bureau  Sensitive  Species  by  the  Oregon  State 

Director 

■  Observed;  on  BLM-A.  on  other  lands  in  the  SYUs  -  B,  Unobserved  -  C. 

Animals 
Terrestrial  Animals 

Animal  distribution,  diversity  and  abundance 
are  dependent  on  various  factors:  of  primary 
importance  is  vegetation.  Each  vegetational  zone 
described  in  the  previous  section  contains  a 
variety  of  plant  communities  which  may  be  in 
different  successional  stages.  Each  successional 
stage  has  a  unique  structure,  and  it  is  primarily 
this  structure  to  which  animal  communities 
respond.  The  differences  in  communities, 
successional  stages  and  structure  provide  habitat 
diversity  and  account  for  the  variety  of  animals 
found  in  the  planning  area. 


Successional  stages  are  dynamic.  They  are  always 
progressing  toward  their  climax  form,  and  during 
this  progression  their  animal  components  are  also 
changing.  Progress  toward  climax  can  be  curtailed 
at  any  point  by  outside  influences,  either  natural  or 
artificial.  For  instance,  fire  or  logging  may  set  back 
succession,  and  those  animal  species  associated 
with  the  current  stage  will  be  replaced  with  those 
adapted  to  exist  in  the  early  successional  stages. 

Modifying  or  removing  one  particular  stage,  e.g., 
old  growth,  has  a  significant  effect  on  those 
individuals  and  species  occurring  there.  It  is 
recognized  that  these  effects  do  not  stop  with  just 
those  species,  as  the  ecosystem  as  a  whole  is 
altered  by  the  modification  of  one  of  its  parts. 
Certain  results  may  be  harmful  to  some  species 
and  beneficial  to  others,  but  all  are  affected. 


40 


There  are  32  species  of  amphibians  and  reptiles, 
184  species  of  birds  and  70  species  of  mammals 
that  occur  or  probably  occur  in  the  planning  area. 
Some  species  of  animals  are  quite  restricted  in 
their  habitat  requirements,  while  others  have  a 
wide  tolerance.  For  instance,  the  robin  occurs  in 
most  habitat  types  while  the  northern  spotted  owl 
is  much  more  restricted. 

Appendix  D  lists  those  species  of  terrestrial 
vertebrates  occurring  in  the  planning  area,  some 
information  on  their  habitat  requirements  and  what 
is  known  of  the  status  of  their  population  and 
habitat. 

From  the  perspective  of  all  ownerships,  the 
progression  toward  climax  on  intensively  managed 
lands  in  the  SYUs  has  been  halted  and  reverted  to 
early  successional  stages  by  planned  timber 
management  activities.  In  1930,  for  example,  most 
of  the  forest  land  acreage  supported  mature  and 
old  growth  stands.  The  most  recent  inventories 
(Appendices  E  and  F)  show  (Table  2-8)  a  greater 
diversity  than  that  which  existed  under  more 
"natural"  conditions  50  years  ago. 

The  present  diversity,  however,  is  a  transitory 
condition.  The  forest  management  activities  that 
created  the  current  diversity  on  the  commercial 
forest  land  base  will,  if  carried  to  the  planned 
conclusion,  result  in  a  situation  where  the  oldest 
forest  stands  will  be  80  years  of  age.  Since 
approximately  71  percent  of  the  area  is  not 


controlled  by  the  BLM,  this  is  the  situation  that  is 
most  likely  to  occur  on  most  of  the  area. 

Habitat  structure  for  all  lands  within  the  SYUs 
regardless  of  ownership  or  administration  cannot 
be  accurately  calculated.  However,  based  on  data 
from  a  variety  of  sources,  habitat  structure  for  the 
entire  area  was  estimated  for  all  forest  lands  and  is 
shown  in  Table  2-10.  The  "all  lands"  category 
consists  of  forest  lands  within  Douglas  County 
east  of  the  crest  of  the  Coast  Range.  Total  land 
area  is  approximately  1.4  million  acres.  Bureau 
forest  lands  in  the  table  approximate  404,000 
acres. 

Old-growth  forests  provide  optimum  habitat  for  a 
variety  of  animal  species  (see  Appendix  D)  and  are 
important  to  the  entire  forest  ecosystem  (Franklin 
etal.  1981).  Old-growth  habitat  totals  110,900 
acres  or  27  percent  of  Bureau-managed  forest 
lands  in  the  SYUs  (Tables  2-8  and  2-10). 

Other  types  of  habitat  exist  and  can  be  modified 
by  forest  management  practices.  Of  special 
concern  are  snags.  Snags  provide  optimum  habitat 
for  33  species  and  are  used  to  some  extent  by  47 
other  species  of  birds  and  mammals  in  the  SYUs 
(see  Appendix  D).  That  cavity-nesting  birds  feed 
on  insects  and  play  an  important  part  in  control  of 
forest  insect  pests  has  been  well  reviewed  by 
Thomas  (1979). 


Table  2-10  Habitat  Structure  of  Forest  Lands 

in 

the  SYUs  (by  percent) 

BLM  Habitat 

Habitat  Age 

All  Forest 
Lands 

BLM 

as  a 
Percent  of  All 
Forest  Lands* 

Grass/Forb 
(non-stocked  and  0-7 

years) 

15 

9 

16 

Brush/Seedling 
(8-15  years) 

17 

10 

17 

Pole/Sapling 
(16-45  years) 

25 

14 

16 

Young  2nd  Growth 
(46-115  years) 

18 

20 

32 

Mature 
(116-195  years) 

9 

20 

66 

Old  Growth 
(196+  years) 

16 

27 

47 

"  This  column  indicates,  for  example,  that  while  27  percent  of  BLM  land  is  old  growth,  this  is  47  percent  of  all 

old  growth  in  the  defined  area 

Source:  USDI,  BLM.  USOA.  FS 

;  Oregon  Department  of  Forestry; 

Oregon  Division  of  Parks  and  Recreation 

41 


Under  natural  conditions,  snags  occur  throughout 
the  forest  as  a  result  of  fire,  disease  and  other 
factors.  Timber  harvest  practices  generally  result 
in  their  removal  for  safety  and  fire  prevention. 
Recent  snag  surveys  by  district  personnel  revealed 
an  average  of  0.1  snags  per  acre  in  coniferous 
forests  less  than  15  years  of  age  under  BLM 
administration.  Due  to  the  large  amount  of  older 
forest  lands,  snag  densities  are  currently  at  high 
levels,  although  distribution  is  not  even. 

Riparian  zones  are  an  extremely  important  habitat 
because  they  are  used  to  a  greater  extent  by  a 
greater  variety  of  species  than  any  other  habitat. 
Of  the  286  species  of  terrestrial  vertebrates  found 
in  the  planning  area,  82  find  their  optimum  habitat 
in  riparian  zones  while  another  170  species  use 
this  habitat  for  part  of  their  overall  needs  (see 
Appendix  D). 

In  western  Oregon  riparian  zones  vary  in  width; 
generally,  the  larger  the  stream  the  wider  the 
riparian  zone.  Vegetation  within  these  areas 
includes  plants  only  found  in  association  with 
water  as  well  as  others  including  hardwoods  and 
merchantable  softwoods. 

Currently,  there  are  about  22,800  acres  of  riparian 
habitat  on  BLM-administered  lands  in  the  SYUs 
(USDI,  BLM  1980a).  Approximately  12,150  of  these 
acres  are  along  small  first  and  second  order 
streams.  Because  of  the  intermittent  nature  of 
these  streams,  the  riparian  habitat  is  not  as  well 
developed  as  on  larger  rivers  and  is  more  nearly 
like  the  adjacent  upland  habitat. 

The  riparian  habitat  on  third  order  and  larger 
streams  represents  about  3  percent  of  the  forest 
land  base.  Some  of  this  has  been  altered  by  past 
timber  management  practices  and  is  in  less  than 
optimum  condition. 

Elk  are  not  evenly  distributed.  While  limited 
numbers  in  scattered  herds  do  occur  in  the  other 
areas,  elk  are  concentrated  in  the  Tyee  area,  which 
includes  Powell,  Basin,  Wolf,  Cougar  and  Hubbard 
Creek  drainages.  Habitat  on  BLM  lands  in  this  area 
is  currently  in  the  following  condition: 


Forage  Area 

Hiding  and  Escape 
Cover 

Thermal  Cover 

Survival  Cover 

0-15  years 

16-45  years 

46-120  years 

120*  years 

15% 

17% 

12% 

56% 

*  Survival  cover  can  be  substituted  for  thermal  cover  but  thermal  cover 

can  not  be  substituted  for  survival  cover 
Source  USDI,  BLM  1980a  and  district  personnel. 

The  mature  and  old  growth  components  are 
important  to  elk  if  optimum  or  near  optimum 
populations  are  to  occur.  In  times  of  extreme 
temperatures  they  function  as  survival  cover, 
providing  forage,  temperature  moderation  and 
snow  interception  (Jenkins  and  Starkey  1980,  De 
Calesta  and  Witmer  1980,  Smithey  et  al.  1982). 
Much  of  the  adjacent  land  under  other  ownership 
has  been  cut  over  and  provides  forage  and  escape 
cover.  It  is  primarily  Bureau-managed  lands  that 


supply  the  thermal  cover  component. 

Fish 

Salmonids  are  the  most  important  group  of 
fish  found  in  the  SYUs.  Other  native  species  such 
as  sculpins,  suckers,  dace  and  squawfish  are  also 
present  within  the  area. 

Introduced  species  such  as  brown  bullhead, 
smallmouth  bass,  largemouth  bass  and  shad  are 
also  present  and  becoming  an  important  fishery. 
With  the  exception  of  information  concerning 
salmonids  in  the  North  Umpqua  River,  there  is 
little  population  data  available.  There  is  even  less 
available  when  limited  to  BLM  land.  It  can  be 
assumed  that  current  habitat  conditions  and  fish 
populations  reflect  past  land  management  actions 
and  fish  harvest  regulations.  In  the  case  of 
anadromous  fish,  the  ocean  habitat  becomes  a 
third  component  influencing  population  levels. 

Timber  management  on  all  lands  has  been  the 
most  significant  land  management  action. 
Changes  in  timber  management  practices 
beginning  in  the  1960's  and  natural 
reestablishment  of  streamside  vegetation  on  lands 
logged  earlier  have  resulted  in  an  improvement  to 
stream  fish  habitat. 

To  some  extent,  all  salmonids  have  the  same  or 
similar  habitat  requirements  such  as  temperature, 
dissolved  oxygen,  spawning  habitat  and  food 
supplies.  Although  there  are  strong  similarities  in 
some  streams,  there  are  highly  varied  population 
levels  when  one  species  is  compared  to  another 
(see  Table  2-11). 

The  North  Umpqua  Resource  Area  is  rated  as 
good  spring  cninook  habitat  and  fair  fall  Chinook 
habitat.  Both  races  have  similar  habitat 
requirements  but  the  North  Umpqua  has  never 
supported  comparable  populations.  Similar 
comparisons  can  be  made  between  summer  and 
winter  steelhead  or  steelhead  and  coho  salmon. 

Recognizing  these  and  other  differences,  Table  2- 
11  was  prepared  showing  information  by  BLM 
Resource  Area.  Examples  of  streams  in  each 
resource  area  are  as  follows: 

Drain  Resource  Area:  Smith  River  and  Wolf 
Creek 

North  Umpqua  Resource  Area:  North  Umpqua 
and  Little  River 

South  Umpqua  Resource  Area:  Myrtle  Creek  and 
Days  Creek 

Dillard  Resource  Area:  Cow  Creek  and  12  Mile 
Creek 


42 


Table  2-11  Salmonid  Fish  Habitat  and  Populations 


Drain  Resource  Area 

Miles  of  Habitat  (BLM) 

Miles  of  Habitat  (other  ownership) 

Habitat  Quality 

Wild  Fish  Population  Trend 

Hatchery  Supplement 

North  Umpqua  Resource  Area 

Miles  of  Habitat  (BLM) 

Miles  of  Habitat  (other  ownership) 

Habitat  Quality 

Wild  Fish  Population  Trend 

Hatchery  Supplement 

South  Umpqua  Resource  Area 

Miles  of  Habitat  (BLM) 

Miles  of  Habitat  (other  ownership) 

Habitat  Quality 

Wild  Fish  Population  Trend 

Hatchery  Supplement 

Dillard  Resource  Area 

Miles  of  Habitat  (BLM) 

Miles  of  Habitat  (other  ownership) 

Habitat  Quality 

Wild  Fish  Population  Trend 

Hatchery  Supplement 


Key 

E  =  Excellent 
G  =  Good 


Spring 

Fall 

Chinook 

Chinook 

Cohc 

9 

20 

79 

46 

66 

255 

1 

F 

P 

' 

S 

D 

No 

No 

2 

8 

8 

18 

71 

71 

105 

G 

F 

P 

S 

S 

D 

40%' 

No 

2 

2 

26 

46 

46 

142 

P 

P 

P 

D 

I 

D 

No 

No 

No 

6 

24 

— 

44 

147 

— 

P 

I 

P 
D 

— 

No 

No 

F  =  Fair 
P  =  Poor 


S  =  Stable 
I  =  Increase 


D  =  Decrease 


1  Only  present  during  passage  to  and  from  the  ocean. 

2  Release  of  hatchery  reared  smolts  initiated  but  too  soon  for  adult  returns. 

3  Percentage  of  total  adult  run  attributable  to  hatchery  reared  smolts. 

"  Percentage  of  trout  harvest  attributable  to  hatchery  reared  legal  sized  fish. 

Source:  USDI,  BLM  1980a,  and  BLM  district  personnel. 


Winter 

Summer 

Steel- 

Steel- 

Sea-run 

Resident 

head 

head 

Cutthroat 

Trout 

79 

9 

79 

108 

255 

46 

255 

297 

F 

P 

F 

S 

' 

D 

D 

No 

No 

No 

No 

34 

28 

34 

57 

154 

45 

154 

275 

F 

G 

P 

F 

S 

S-l 

D 

S 

No 

50%' 

No 

95%' 

26 

26 

57 

142 

— 

142 

214 

P 

— 

P 

F 

S-l 

— 

D 

S-D 

50% 

— 

No 

95%4 

24 

24 

48 

147 

— 

147 

162 

F 

— 

P 

F 

S-l 

— 

D 

D 

50% 

— 

No 

No 

Table  2-12  Threatened  and 

Endangered  Species  of  the 

Roseburg  SYUs 

Federal 

Oregon 

Species 

Status 

Status 

Northern  bald  eagle 

T 

T 

Haliaeetus 

leucocephalus 

alascanus 

Northern  spotted  owl 

T 

Strix  occidentalis 

caurina 

Columbian  white-tailed  deer 

E 

E 

Odocoileus  virginianus 

leucurus 

T  =  Threatened 

E     Endangered 

Threatened  and  Endangered 
Animals 

There  are  three  species  of  animals 
officially  listed  by  the  U.S.  Fish  and  Wildlife 
Service  and/or  the  State  of  Oregon  as  threatened 
or  endangered  that  occur  at  least  occasionally  in 
the  SYUs.  Table  2-12  lists  those  species  and  their 
status. 

The  bald  eagle  is  a  regular  inhabitant  of  the  SYUs 
and  there  are  two  pairs  known  to  nest  on  BLM- 
administered  land. 

The  northern  spotted  owl  is  a  permanent  resident 
of  the  SYUs.  On  Bureau-administered  lands,  there 
are  55  habitat  units,  each  known  to  support  one 
pair  of  owls.  An  additional  30  locations  have  been 
identified  as  occasionally  containing  owls.  These 
may  be  juveniles  or  single  birds.  Inconsistent 
sighting  and  the  quality  of  the  habitat  make  it 
unlikely  these  areas  are  capable  of  supporting 
breeding  pairs. 


43 


The  55  habitat  units  were  judged  to  be  in  the 
following  condition: 

Poor  4  Very  Good  1 1 

Fair  12  Excellent  9 

Good  19 

The  criteria  used  to  judge  the  conditions  were: 

Poor  =  <1 50  acres  old  growth 

1,050  acres  <80  years 

Fair  =  <300  acres  old  growth 

900  acres  <120  years 

Good  =  300+  acres  old  growth 

450  acres  30-200  years 
450  acres  <30  years 

Very  Good  =      500+  acres  old  growth 
200  acres  120-200  years 
200  acres  30-120  years 
300  acres  <30  years 

Excellent  =         700+  acres  old  growth 
200  acres  120-200  years 
100  acres 30-1 20  years 
200  acres  <30  years 

In  the  opinion  of  the  BLM  district  biologist,  those 
units  in  the  poor  habitat  category  are  extremely 
marginal  and  will  eventually  fail  to  support  owls. 

An  additional  63  pairs  of  owls  have  been  recorded 
on  lands  of  other  ownership  within  the  planning 
area,  primarily  on  lands  administered  by  the  U.S. 
Forest  Service. 

The  Columbian  white-tailed  deer  is  a  resident  of 
the  oak-ash  bottom  lands  and  the  oak-madrone 
uplands  and  is  found  on  Bureau-managed  lands, 
but  predominantly  on  lands  in  other  ownerships. 

The  U.S.  Fish  and  Wildlife  Service  has  not 
designated  any  critical  habitat  under  Section  4  of 
the  Endangered  Species  Act  within  the  SYUs. 
However,  BLM  identified  essential  habitat  totaling 
37  acres  for  the  Columbian  white-tailed  deer  and 
3,475  acres  for  the  bald  eagle  was  delineated  in  the 
SYUs  and  recommended  to  the  U.S.  Fish  and 
Wildlife  Service  for  further  consideration. 


Recreation 


Developed  recreation  sites  on  public  land  include 
Gunter,  Tyee,  Lone  Rock,  Mill  Pond,  Rock  Creek, 
Scaredman,  Susan  Creek  Recreation  Area,  Cavitt 
Creek,  Wolf  Creek  Trail  and  Emile  (see  Figure  1-1). 
Each  site  (except  trails)  has  facilities  for  overnight 
camping  and/or  picnicking.  Annual  use  at  the  10 
developed  sites  is  approximately  19,000  visitor 
days,  with  about  43  percent  attributable  to 
overnight  use.  Opportunities  are  also  available  for 
dispersed  camping  and  picnicking  throughout  the 
SYUs. 


Fishing  for  anadromous  species  is  a  major 
recreational  activity  in  the  SYUs.  Some  fishing  for 
trout  and  warm  water  game  fish  also  occurs.  Most 
stream  fishing  use  is  in  the  Umpqua  (Main,  North 
and  South),  Smith  and  Little  Rivers,  Rock  Creek 
and  Cow  Creek.  The  North  Umpqua  River  is 
nationally  known  for  its  anadromous  fishery. 

The  major  hunting  activity  on  public  land  is  for 
deer  and  elk.  Hunter  success  is  affected  by  game 
populations,  ease  of  movement  and  shooting 
opportunities.  Hunting  with  hounds  for  bear  and 
cougar  also  occurs  throughout  the  SYUs. 

Most  general  sightseeing  use  occurs  in  association 
with  travel  along  major  roads.  Some  people  also 
visit  public  lands  with  specific  sightseeing  goals  or 
may  include  sightseeing  as  a  part  of  other 
activities.  Examples  of  such  areas  with 
opportunities  for  this  use  include  the  North 
Umpqua  River  Highway,  Cavitt  Creek  Falls,  Maude 
"S"  Mine,  Susan  Creek  Indian  Mounds,  Main  and 
South  Umpqua  River,  Susan  Creek  Falls,  Wolf 
Creek  Falls  and  a  number  of  scenic  overlooks. 

High  quality  opportunities  are  available  for 
swimming,  canoeing,  kayaking  and  floatboating. 
Most  use  occurs  on  the  Umpqua  River  (Main, 
North  and  South  Forks)  and  Cow  Creek.  Off-road 
vehicle  (ORV)  use  in  the  SYUs  is  generally  limited 
to  existing  roads  and  trails.  In  recent  years  this 
recreational  use  has  increased  rapidly.  Although 
use  is  low,  opportunities  are  available  for  areawide 
berry  picking  and  horseback  riding,  goldpanning 
and  rock  collecting. 

The  Nationwide  Rivers  Inventory  prepared  by  the 
Heritage  Conservation  and  Recreation  Service 
(HCRS)  and  National  Park  Service  (NPS)  has 
identified  sections  of  the  Umpqua  and  North 
Umpqua  as  potential  national  wild,  scenic  or 
recreational  rivers  crossing  public  land  within  the 
SYUs  (USDI,  HCRS  1980).  The  North  Umpqua 
River  has  also  been  identified  by  the  State  of 
Oregon  for  potential  State  Scenic  Waterway 
designation.  The  State  Transportation 
Commission  reviewed  the  study  but  chose  not  to 
continue  the  designation  process  for  the  North 
Umpqua  River  (Lilly  1981). 

Table  2-13  summarizes  visitation  attributable  to 
major  recreation  activities  in  the  SYUs. 
Recreational  demand  projections  to  1990  are  also 
displayed. 

Cultural  Resources 

BLM  is  required  by  law  and  executive  order 
to  identify,  protect  and  enhance  significant 
cultural  resources  on  public  lands.  A  number  of 
procedures,  including  those  specified  in  36  CFR 
800.4(a),  were  used  to  identify  the  cultural 
resources  within  the  SYUs. 


44 


Table  2-13  Estimated  Current  and  Projected  Visitation  Attributed  to  Major 
Recreation  Activities 

Activity 

Current  Visitation1 
Visitor  Days/Year 

1990  Demand  Projection2 
Visitor  Days/Year 

Total3 
(Douglas 
County) 

BLM 

(Roseburg 

District) 

Total3 
(Douglas 
County) 

BLM 

(Roseburg 

District) 

Hunting 

Big  game 
Upland  game 

194,060 
35,120 

23,250 
2,510 

204,630 
37,330 

24,460 
2,670 

Fishing 

All  anadromous 
Resident  cold-water 
Resident  warm-water 

124,000 

103,800 

5,200 

23,670 

19,190 

490 

186,000 
129,750 
10,400 

35,510 

23,990 

980 

Camping 
Hiking 

Horseback  riding 
Hound  sports 
ORV  use 
Other  day  use4 
Total 

796,300 

23,560 

25,390 

182,330 

500,330 

598,670 

2,588,760 

8,220 

420 

460 

3,280 

9,010 

10,780 

101,280 

978,000 

28,940 

31,180 

223,930 

614,500 

735,270 

3,184,930 

10,100 

520 

560 

4,030 

11,070 

13,240 

127,130 

1  Based  on  data  collected  between  1976-1978 

:  Based  upon  projections  in  USDI,  BLM  (1980b),  conversations  with  Oregon  Department  of  Fish 

Transportation  (1978) 

1  Total  visitation  includes  use  in  the  coastal  region  where  public  lands  are  limited. 

*  Total  area  day  use  visitation  excludes  urban  and  semi-urban  activities  not  generally  associated 

and  Wildlife  staff  and  Oregon  Department  of 
with  forest  lands  administered  by  BLM 

Source:  USDI.  BLM  1980b. 

A  survey  of  existing  cultural  resource  information 
(Class  I  survey)  has  been  completed  for  the  SYUs 
(Honey  and  Hogg  1980)  through  a  compilation  of 
the  area's  existing  site  record  data.  A  thorough 
survey  to  locate  and  identify  cultural  resources  is 
accomplished  prior  to  ground  disturbance  or 
ownership  changes.  The  results  of  this  intensive 
survey  are  documented  in  each  site  specific 
environmental  assessment. 

The  criteria  used  to  assess  the  eligibility  of 
identified  cultural  resources  for  inclusion  in  the 
National  Register  of  Historic  Places  are  described 
in36CFR  1202.6. 

Prehistoric  Sites 

While  little  of  the  area  has  been  field 
surveyed  for  prehistoric  resources  due  to  its  steep, 
heavily  forested  terrain,  there  are  90  recorded 
prehistoric  sites  on  or  near  public  land  within  the 
SYUs  (Honey  and  Hogg  1980).  Most  are  trailside 
and/or  hunting  camps  associated  with  Indian  use 
of  upland  resources.  An  area's  available  resources 
such  as  water,  plant  and  animal  foods,  workable 
stone,  or  amenable  terrain  probably  determined 
the  nature  and  location  of  sites. 

Examples  of  areas  within  the  SYUs  which  exhibit  a 
relatively  high  density  of  prehistoric  sites  include 


Upper  Little  River,  Susan  Creek  vicinity,  Upper 
Middle  Creek,  Camas  Valley-Boulder  Creek  and 
the  White  Rock-Dompier  Creek  Region. 

A  group  of  rock  mounds  in  the  Susan  Creek 
vicinity  is  currently  listed  on  the  National  Register 
of  Historic  Places  (see  Glossary). 

Historic  Sites 

There  are  41  inventoried  historic  sites  on 
or  near  BLM-administered  land  within  the  SYUs 
(Honey  and  Hogg  1980).  About  80  percent  of  the 
sites  have  not  been  formally  recorded  and  are  in 
need  of  further  documentation.  Most  historic  sites 
in  the  SYUs  relate  to  fur  trade,  settlement, 
transportation,  mining  and  logging.  None  of  the 
historic  sites  on  public  land  is  currently  listed  on 
the  National  Register  of  Historic  Places. 

Paleontologic  Sites 

No  important  or  scientifically  unique 
paleontologic  sites  have  been  identified  in  the 
SYUs.  However,  all  reports  of  fossil-bearing 
deposits  are  examined  by  qualified  personnel  to 
avoid  destruction  of  such  resources. 


45 


Visual  Resources 

Visual  resources  are  the  land,  water, 
vegetation,  animals  and  the  other  features  (as 
described  in  this  chapter)  that  are  visible  on  public 
lands.  Visual  resource  management  (VRM) 
objectives  have  been  developed  based  on  three 
factors  (BLM  Manual  8400).  These  factors  are 
scenic  quality,  visual  sensitivity  and  distance  zone 
(see  Glossary).  Examples  of  high  to  moderate 
scenic  quality  and  visually  sensitive  areas  on 
public  land  include  Coles  Valley,  Umpqua  River, 
Berry  Creek  Reservoir,  Bushnell  Rock,  Susan 
Creek  Falls,  North  Umpqua  River,  Cooper  Creek 
Reservoir  and  portions  of  the  viewshed  from 
Interstate  5. 

VRM  classes  specify  management  objectives  and 
allow  for  differing  degrees  of  modification. 
Objectives  for  each  VRM  class  follow: 

Class  I:  Provides  primarily  for  natural  ecological 
change  (highest  levels  of  protection).  Generally 
includes  highly  scenic  and/or  highly  sensitive 
areas. 

Class  II:  Changes  in  any  of  the  visual  resource 
basic  elements  (see  Glossary)  caused  by  a 
management  activity  should  not  be  evident  in  the 
characteristic  landscape.  A  change  may  be  seen 
but  should  not  attract  attention  (retention  of 
scenic  quality).  Generally  includes  areas  with  high 
to  moderate  scenic  quality  and/or  sensitivity. 

Class  III:  Changes  in  the  basic  elements  caused  by 
a  management  activity  may  be  evident  in,  but 
should  remain  subordinate  to,  the  existing 
characteristic  landscape  (partial  retention  of 
scenic  quality).  Generally  includes  moderate 
scenic  quality  and/or  sensitivity. 

Class  IV:  Changes  may  attract  attention  and  be 
dominant  landscape  features  but  should  reflect 
those  basic  elements  inherent  in  the  characteristic 
landscape  (modification  of  scenic  quality  -  lowest 
level  of  protection).  Generally  includes  areas  with 
moderate  to  low  scenic  quality  that  are  seldom 
seen. 

Figure  2-3  shows  VRM  classes  as  recommended 
through  the  visual  resource  inventory  and 
evaluation  of  the  existing  environment. 

Wilderness  Values 

Under  the  terms  of  the  Federal  Land  Policy 
and  Management  Act  of  1976  (FLPMA),  roadless 
areas  of  5,000  acres  or  more  that  have  wilderness 
characteristics  are  to  be  reviewed  within  15  years 
for  possible  wilderness  designation.  The  1976  Act 
also  states  that  in  the  event  of  inconsistency 
between  it  and  the  O&C  Act  insofar  as  they  both 
may  relate  to  management  of  timber  resources,  the 
O&C  Act  prevails.  Accordingly,  the  wilderness 


review  provisions  do  not  apply  to  revested  Oregon 
and  California  Railroad  grant  lands  suitable  for 
sustained  yield  management  as  commercial  timber 
lands. 

No  areas  within  the  SYUs  are  proposed  wilderness 
study  areas.  The  intensive  wilderness  inventory 
and  accompanying  maps  for  Oregon  and 
Washington  are  available  in  the  Oregon  State 
Office. 

Areas  of  Critical 
Environmental  Concern 

Areas  of  Critical  Environmental  Concern 
(ACECs)  are  areas  within  the  public  lands  where 
special  management  attention  is  required  to 
protect  and  prevent  irreparable  damage  to 
important  historic,  cultural,  or  scenic  values,  fish 
and  wildlife  resources,  or  other  natural  systems  or 
processes,  or  to  protect  life  and  safety  from 
natural  hazards  (FLPMA  Section  103(a)). 
Designation  of  an  area  as  an  ACEC  does  not 
necessarily  preclude  development  but  rather 
ensures  the  protection  of  sensitive  values  in  those 
cases  where  appropriate  development  may  take 
place.  Following  designation,  activity  plans  are 
prepared  to  translate  special  management 
requirements  for  each  area  into  on-the-ground 
implementation  actions. 

Of  the  15  areas  nominated  for  ACEC  consideration 
during  the  Roseburg  District's  planning  process 
(see  Table  2-14),  seven  were  found  to  be  qualified 
for  ACEC  designation.  The  decision  to  designate 
any  or  all  of  these  areas  as  ACECs  will  be  part  of 
the  Management  Framework  Plan  decision  for  the 
SYUs,  to  be  made  following  completion  of  this  EIS. 


Special  Areas 


The  28-acre  Myrtle  Island  timber 
preservation  area  (see  Glossary)  was  established 
in  1951  by  Public  Land  Order  Number  754  to 
preserve  an  old  growth  stand  of  Oregon  myrtle. 
This  Umpqua  River  island  also  has  scattered  old 
growth  Douglas-fir  (Franklin  et  al.  1972).  Further, 
the  area  is  a  designated  Research  Natural  Area 
(see  Glossary).  Myrtle  Island  has  also  been 
identified  by  the  National  Park  Service  (NPS)  as  a 
potential  National  Natural  Landmark  (Chilcoteet 
al.  1976).  Designation  of  a  site  as  a  National 
Natural  Landmark  (see  Glossary),  a  program 
administered  by  the  NPS,  is  not  a  land  withdrawal 
and  would  not  affect  BLM  jurisdiction  to  manage 
the  area. 

Beatty  Creek  is  a  designated  Research  Natural 
Area  (RNA).  This  173-acre  area  has  a 
representation  of  Jeffrey  pine  on  serpentine  soil  in 
the  Siskiyou  Mountains  physiographic  province. 


46 


Table  2-1 4  Nominated  and  Potential  Areas  of  Critical  Environmental  Concern 


Approximate 
Site  Name  Size  (acres)  Description 

QUALIFIED  FOR  ACEC  DESIGNATION1 


Primary 
Resource  Values 


Remarks 


1   Brad's  Creek 

137 

2.  Golden  Bar 

217 

3.  North  Umpqua  River 

1,620 

4.  Tater  Hill 

169 

5.  Myrtle  Island 

28 

6.  Beatty  Creek 


7.  North  Myrtle  Creek 
(Slideover) 


Old  growth  forest,  bald  eagle  habitat 

Old  growth  forest,  bald  eagle  habitat, 
cultural  resources 

Anadromous  fishery,  high  scenic  value 

Large,  active  landslide 


28  Old  growth  Oregon  myrtle  and  Douglas-fir 


173  Pure  stand  of  Jeffrey  Pine  and  a  grass 

community  on  serpentine  soils  at  low 
elevation 

480  Coniferous  forest  mixture  in  the  Umpqua 

River  Valley 


Wildlife,  Scenic 
Wildlife,  Scenic 

Wildlife,  Scenic 

Geologic  Proposed 

Research  Natural 
Area  (RNA) 

Botanic,  Scenic       Currently 

designated  RNA 
and  timber 
preservation  area 

Botanic  Designated  RNA 


Botanic 


Proposed  RNA 
(240  acres) 


NOMINATED  BUT  NOT  QUALIFIED  FOR  ACEC  DESIGNATION2 


1   Whistler's  Woodlands 


22 


2.  Bluff  Creek  Bluffs 

120 

3.  Rice-Bushnell  Divide 

40 

4.  Canyon  Mountain 

80 

5.  North  Myrtle  Creek 
Watershed 

13,100 

6  Wood  Creek 

360 

7.  Dompier  Creek 

240 

Oak  woodlands,  Columbian  white-tailed  Wildlife 
deer  habitat 

Candidate  threatened  or  endangered  plant  Botanic 

Candidate  threatened  or  endangered  plant  Botanic 

Candidate  threatened  or  endangered  Botanic 
plants 

Large,  geologically  complex  basin  Natural  Hazard 

Old  growth  timber,  spotted  owl  habitat  Wildlife 

Several  landslides,  slump  ponds  Geologic  Hazard 


'  Two  identification  criteria  (relevance  and  importance)  derived  from  the  Federal  Land  Policy  and  Management  Act  (1976)  were 
applied  to  evaluate  all  areas  nominated  for  ACEC  designation.  While  Myrtle  Island,  Beatty  Creek  and  North  Myrtle  Creek  met  these 
criteria,  other  measures  would  be  adequate  to  protect  the  significant  resource  values  in  these  areas.  Myrtle  Island  and  Beatty  Creek 
are  currently  designated  Research  Natural  Areas.  North  Myrtle  Creek  is  a  proposed  Research  Natural  Area. 

2  Areas  failed  to  meet  the  criteria  of  importance,  as  described  in  the  August,  1980  Final  Guidelines  for  Areas  of  Critical  Environmental 
Concern  (USDI.  BLM  1980d). 


Other  areas  with  potential  for  RNA  designation 
include  Woodruff  Canyon  lands,  Old  Fairview, 
Tater  Hill  and  North  Myrtle  Creek.  The  Little  River 
Arch  has  potential  for  Outstanding  Natural  Area 
(see  Glossary)  designation.  Red  Pond  is  a 
proposed  environmental  education  area. 

The  BLM  currently  has  five  environmental 
education  use  permits  on  public  land.  These 
permits  provide  for  environmental  education  and 


study  of  public  land  resources  but  do  not  involve 
special  designation  or  facility  development. 

Socioeconomic  Conditions 

During  1975  through  1977  logs  from  the 
Roseburg  District  were  trucked  to  destinations  in 
Douglas  (89.9  percent),  Lane  (7.3  percent),  Coos 
(1.9  percent),  Josephine  (0.1  percent)  and  Jackson 
counties  (0.8  percent).  These  five  counties  taken 


FIGURE  2-3 

VISUAL  RESOURCE 
MANAGEMENT  CLASSES 


U.  S.  DEPARTMENT  OF  THE  INTERIOR 

BUREAU  OF  LAND  MANAGEMENT 
ROSEBURC  DISTRICT 

DOUGLAS  AND  SOUTH  UMPQUA 
SUSTAINED  YIELD  UNITS 

Roseburg  Environmental  Impact  Statement  Area 

1982 


49 


together  are  evaluated  here  as  the  regional 
economy  affected  by  the  action. 

The  region  is  divided  by  the  Coast  Range  into  an 
eastern  section  with  a  larger  and  more  dispersed 
population  in  the  Willamette,  Umpqua  and  Rogue 
River  Valleys  and  a  western  section  with  a  smaller 
population  concentrated  near  Coos  Bay  and  in  the 
Coquille  River  Valley. 

The  average  level  and  recent  changes  in 
population,  employment,  personal  income  and 
public  revenue  within  the  regional  economy  are 
the  quantitative  indicators  of  social  well-being 
discussed  below.  Although  this  is  not  a  complete 
list,  these  four  indicators  were  selected  because 
other  indicators  tend  to  move  consistently  up  or 
down  with  them  and  these  data  have  been 
tabulated  similarly  for  a  number  of  years. 

As  shown  in  Table  2-15,  the  population  of  the 
region  has  increased  more  than  30  percent  over 
the  last  decade  and  now  exceeds  600,000.  While 
paralleling  a  nationwide  shift  of  population 
westward,  the  rate  of  growth  in  the  region 

Table  2-15  Population,  1960-1980 


exceeded  substantially  the  rate  of  growth  in 
Oregon,  which  in  turn  exceeded  the  population 
growth  rate  in  the  United  States. 

Seventy-four  percent  of  the  region's  population 
growth  has  been  net  migration  into  the  region 
(Seidel  1981).  Surveys  of  recent  immigrants  imply 
that  many  are  coming  to  southwestern  Oregon  in 
search  of  a  perceived  quality  of  life  not  found  in 
major  metropolitan  areas  but  available  in  small 
urban  and  rural  environments  (Stevens  1981).  A 
significant  proportion  of  the  newcomers 
immigrated  to  the  region  without  having  first 
secured  employment  (Stevens  1980). 

This  immigration  plus  an  increase  in  the 
proportion  of  women  employed  or  seeking 
employment  caused  the  labor  force  to  grow  faster 
than  total  employment  (Table  2-16).  For  example, 
in  Douglas  County,  the  annual  rate  of  job  creation 
was  2.17  percent  while  the  labor  force  was 
increasing  at  2.91  percent  annually. 


Annual  Growth  Rate 


County 

1960 

1970 

1980 

1960-70 

1970-80 

Douglas 

Lane 

Coos 

Josephine 

Jackson 

68,458 
162,890 
54,955 
29,917 
73,962 

71,743 
213,358 
56,515 
35,746 
94,533 

93,748 

275,226 

64,047 

58,820 

132,456 

0.5% 

2.7 

0.3 

1.8 

2.5 

2.7% 

2.6 

1.3 

5.1 

3.4 

Region 

390,182 

471,895 

624,297 

1 .9% 

2.8% 

Oregon 

1,768,687 

2,091,533 

2,633,105 

1.7% 

2.3% 

United  States 

179,323,175 

203,235,298 

226,504,825 

1 .3% 

1.1% 

Source:  U.S.  Dept  of  Commerce  Census  of  Population,  years  indicated. 


Table  2-16  Components  of  Population  Change,  1970-1980 


County 

Population 

Change 

1970-1980 

Natural  Increase 

(Births  minus 

deaths) 

Net 
Migration 

Net  Migration 

as  a  Percent  of 

Population  Change 

Douglas 

Lane 

Coos 

Josephine 

Jackson 

22,015 
59,825 
7,532 
23,109 
37,923 

7,332 
19,657 
4,391 
2,224 
5,867 

14,683 
40,168 
3,141 
20,885 
32,056 

67 
67 
42 
90 
85 

Region 

150,404 

39,471 

110,933 

74 

Source:  Personal 
Oregon,  Septemb 

communication, 
er 1981. 

Karen  Seidel,  Bureau 

of  Governmental  Research 

and  Service,  University  of  Oregon,  Eugene, 

50 


Table  2-17  Average  Size  and  Recent  Growth  of  the  Labor  Force  and 
Employment  in  Industries 


Douglas  County 

Regional 

Regional  Economy 

Oregon 

Compound 

Compound 

Compound 

Douglas  County 

Annual  Growth 

Economy 

Annual  Growth 

Oregon 

Annual  Growth 

Avg.  1977-1980 

1972-1980  O) 

Avg.  1977-1980 

1972-1980  ; 

Avg.  1977-1980 

1972-1980  (,) 

l  abor  Force 

38.800 

291 

270.500 

3  75 

1.202.500 

358 

Total  Employment 

35.000 

2  17 

246.300 

3  23 

1.1 16,800 

3  38 

Wage  &  Salary  Empl> 

BOO 

246 

210,900 

1.009.100 

3  77 

All  Manufacturing 

1  0.200 

-1  46 

48.300 

53 

216.600 

1  92 

Lumber  &  Wood 

8.500 

-2  05 

35.100 

-2  64 

77.700 

-1  37 

'  Durable  Goods 

500 

-.81 

6.000 

602 

All  Non-Manufacturing 

20.600 

4  75 

162,500 

4.87 

792,400 

4  30 

5.600 

4  44 

50.100 

5  10 

245.500 

4  67 

Services  &  Miscell.i 

4,300 

683 

35.900 

6  72 

1 78  600 

565 

Government 

6.900 

385 

46,000 

4  05 

196.400 

3  18 

'  Not  comparable  with  the  same  category  for  Douglas  County  or  the  Regional  Economy 

Source  Computations  by  EIS  staff  of  data  obtained  from  the  Research  and  Statistics  Section.  Employment  Division.  Oregon  Dept  of  Human  Resources 


Table  2-18  Total  and  Rate  of  Growth  of 

Labor  and  Proprietors'  Income  in 

Selected  Industries  Affected  by  Timber  Management  in 
District 

the  Roseburg 

Douglas  County 

Avg.  1977-1979 

(S1.000.000) 

Douglas  County           E 
Compound  Annual 
Growth  1972-1979 

Regional 
conomy  Avg. 
1977-1979 
(S1. 000.000) 

Regional  Economy 
Compound  Annual 
Growth  1972-1979 

Oregon 

Avg.  1977-1979 

(S1.000.000) 

Oregon 
Compound  Annual 
Growth  1972-1979 

Total  Labor  and  Proprietors' 

Income  by  place  of  work 

S  493  5 

1 1 .9 

S3.073.5 

12  96% 

S19.792  8 

1 1  40% 

Durable  Goods  Manufacturing 

197  0 

10  1 

837.1 

10.60% 

3.079  1 

11  79% 

Trade 

57.9 

555  2 

13.81% 

2,923.5 

11.25% 

Services 

52.9 

15  !., 

454.8 

15.62% 

2.381  9 

12  40% 

Federal  Gov't.,  Civilian 

26  6 

10.99% 

1023 

12 

505  7 

7  97% 

State  and  Local  Government 

Per  Capita  Personal  Income 
(in  actual  $) 

253.1 
$7,012. 

3689 
S6.984 

12.55% 
10.24 

1.864  2 
S  8.047 

9  76% 
9  38% 

957% 

Source  Computations  by  EIS  staff 
1981. 

obtained  from  the  Regional  Economic  Information  system  US. 

Department  of  Commerce,  Bureau  of  Ecor 

lomic  Analysis.  April 

Employment  and  income  growth  in  the  region's 
trade  and  service  sectors  was  strong  in  the  1970's 
(Tables  2-17  and  2-18).  The  growth  rates  in  the 
region  outpaced  Douglas  County,  which  was 
ahead  of  the  State  totals  in  both  categories.  A 
reduction  of  the  manufacturing  base  in  Douglas 
County  and  a  lack  of  significant  growth  in 
manufacturing  employment  in  the  regional 
economy  during  the  decade  are  of  local  concern 
(C.C.D.  Economic  Improvement  Assoc.  1978, 
1979).  Non-manufacturing  employment  within  the 
region  and  the  State  has  increased,  paralleling  a 
national  trend.  Whether  projected  long-term 
declines  in  lumber  and  wood  products 
employment  (Burden  1977;  Flacco  1978;  C.C.D. 
Economic  Improvement  Assoc.  1978)  can  be  offset 
by  continued  growth  in  the  non-manufacturing 
sector  and  local  programs  promoting 
diversification  is  still  unknown  (Oregon 
Department  of  Human  Resources  1979,  1980; 
C.C.D.  Economic  Improvement  Assoc.  1978,  1979; 
Douglas  County  1980). 


Statewide,  total  employment  in  the  lumber  and 
wood  products  sector  declined  at  a  1.37  percent 
annual  rate  (Table  2-17)  and  total  employment  in 
manufacturing  increased  by  more  than  29,100 
jobs,  an  average  annual  increase  of  almost  2 
percent.  To  date,  much  of  Oregon's  diversification 
and  employment  growth  in  manufacturing  has 
been  in  the  Portland,  Salem,  Eugene-Springfield 
and  Medford  metropolitan  areas.  The  remainder  of 
western  Oregon  continues  to  be  highly  dependent 
on  agriculture  and  lumber  and  wood  products  for 
significant  proportions  of  its  income  and 
employment.  Since  southwestern  Oregon  is 
dominated  by  mountainous  forest  land, 
agricultural  options  are  limited.  Thus, 
overwhelmingly,  the  region's  primary  source  of 
income  continues  to  be  derivatives  of  the  timber 
resource  —  logs,  lumber,  plywood  and  other  panel 
products,  chips,  pulp  and  paper. 


51 


Receipts  from  the  sale  or  use  of  resources  found 
on  O&C,  public  domain  and  Coos  Bay  Wagon 
Road  (CBWR)  lands  are  distributed  to  State  and 
local  governments  through  distribution  formulas 
established  by  Congress  and  the  Oregon 
legislature.  Fifty  percent  of  the  revenue  from  all 
O&C  lands  in  the  State  is  distributed  among  the 
counties  with  O&C  land  in  proportion  to  the  1915 
assessed  value  of  the  O&C  lands  in  each  county. 
Tables  2-19  and  2-20  show  the  importance  of  O&C 
revenue  distribution  to  individual  counties.  The 
summary  data  reported  in  Table  2-19  highlight 
principal  sources  of  revenue  (as  a  percent  of  total) 
and  revenue  per  capita  for  Douglas  County,  all 
counties  in  the  EIS  economic  region  and  all 
counties  in  Oregon.  O&C  revenues  constitute  a 
significant  portion  of  revenue  from  all  sources  for 


Douglas,  Coos,  Lane,  Jackson  and  Josephine 
counties.  The  resulting  high  level  of  public 
revenue  per  capita  gives  these  counties 
opportunities  to  provide  a  diversity  and  level  of 
public  services  more  difficult  to  finance  elsewhere 
in  Oregon  (Jensen  1979).  The  value  of  these 
disbursements  to  the  O&C  counties  can  be 
equated  in  terms  of  property  tax  equivalents— the 
amount  per  $1,000  assessed  value  which  property 
tax  levies  would  have  to  be  increased  to  raise  an 
amount  of  revenue  equal  to  the  county's  share  of 
O&C  receipts. 

Payments  are  made  to  local  governments  from 
CBWR  land  revenues  in  the  form  of  timber 
severance  and  property  taxes.  Severance  tax 
payments  are  distributed  to  local  tax  districts  in 


Table  2-19  County  Revenue 

Sources 

as  a 

Percentage  of  Total  Revenues 

and  County  Revenues  Per  Capita  for  Fiscal  Year  1977-78 

Douglas 

Regional  Economy 

All  Oregon 

Counties 

%  of  Total 

%  of  Total 

%  of  Total 

Source 

Revenues 

Per  Capita         Revenues 

Per  Capita 

Revenues 

Per  Capita 

I.  REVENUES  FROM  OWN  SOURCES 

Tax  Revenues: 

Property  Taxes 

4,2% 

$23.82 

5  2% 

S  16  27 

16.6% 

$35.76 

Other  Taxes 

0,0 

.00 

0.2 

72 

1.7 

56 

Local  Non-tax  Revenues 

Licenses,  Permits, 

Services  Charges  &  Fees 

2.8 

15.67 

4.2 

12.94 

5  1 

1091 

Fines.  Forfeitures  &  Court  Fees 

1.3 

7.22 

1.7 

5.19 

2.0 

4.38 

Interest  Earnings 

40 

2252 

4.0 

1294 

3.4 

742 

Public  Service  Enterprises 

1.7 

9.50 

1.1 

338 

1.9 

4.02 

Other  Local  Non-tax  Revenues 
Subtotal:  Revenues  from  Own  Sources 

1.7 

9.38 

0.7 

2.12 

0.9 

1  99 

17.1% 

S  53  17 

31.6% 

S68  04 

II.  INTERGOVERNMENTAL  REVENUES 

Federal  Revenues: 

General  Revenue  Sharing 

1,1% 

$6.14 

1 .6% 

$4  84 

3.6% 

$7.81 

Federal  Land  Revenue  Sharing: 

National  Forest  Revenues 

198 

111  23 

197 

61.20 

17  4 

37.47 

O&C  Revenues 

564 

317.38 

43.6 

13576 

206 

4426 

Payments  in  Lieu  of  Taxes 

0,2 

1.23 

0.2 

.61 

0.7 

1.48 

Coos  Bay  Wagon  Rd.  Revenues 

0.4 

232 

0.7 

2.04 

02 

49 

Other  Land  Revenue  Sharing 

0.0 

.21 

0.0 

10 

0.2 

37 

Grants-ln-Aid: 

Anti-Recession  Payments 

0.5 

281 

0.5 

1  61 

1  1 

245 

Countercyclical  Public  Works 

0,0 

00 

0.9 

2.95 

1  4 

3.07 

CETA 

0.0 

.25 

1.2 

3.72 

2.7 

583 

Other  Grants-ln-Aid 

0,0 

.00 

3.2 

982 

4.1 

868 

State  Revenues: 

Shared  Revenues 

4  1 

22  99 

6.5 

20  19 

10.9 

2331 

Grants-ln-Aid  &  Others 

1.5 

8.37 

3.5 

10.92 

4  2 

9.12 

Interlocal  Revenues 

Subtotal   Intergovernmental  Revenues 

0.4 

203 

1.3 

82  9 

420 

1.3 

68  4 

269 

03 

96 

TOTAL  REVENUES  FROM 

ALL  SOURCES 

100% 

$56307 

100% 

$311  12 

100% 

S215.07 

Source  Oregon  Bureau  of  Governmental  Research  and  Service.  Revenue  Sources 

•  of  Oregon  Counties  Fiscal  Year 

1977-78.  Informatation  Bulletin 

No   171,  Eugene.  Oregon,  June  1979. 

52 


Table  2-20  O&C  Revenue  Distribution  to  Counties  Expressed  As  Property 
Tax  Rate  Equivalent  and  As  Percent  Supplement  to  Total  Levy,  Fiscal 
Years  1977-1980 


County 


Amount  per  $1,000  Assessed  Value1 

1977  1978  1979  1980 


Percent  Supplement  to  Levy2 

1977  1978  1979  1980 


Benton 

$3.36 

$2.26 

$2.03 

$2.05 

21.9 

12.3 

12.4 

10.5 

Clackamas 

1.69 

1.17 

1.01 

.90 

6.8 

5.4 

5.5 

46 

Columbia 

2.20 

1.77 

1.86 

1.86 

15.2 

12.7 

13.0 

11.7 

Coos 

6.59 

5.32 

4.81 

4.59 

30.9 

31.9 

29.0 

25.3 

Curry 

13.27 

9.81 

8.38 

7.09 

120.2 

102.1 

92.9 

109.2 

Douglas 

14.47 

12.44 

11.59 

11.50 

90.0 

110.3 

103.8 

79.5 

Jackson 

9.78 

6.90 

5.85 

5.51 

50.5 

39.3 

41.2 

330 

Josephine 

18.23 

11.78 

10.04 

9.56 

119.1 

74.4 

89.8 

63.0 

Klamath 

2.47 

1.85 

1.73 

1.68 

17.3 

13.4 

13.7 

11.7 

Lane 

3.92 

2.91 

2.48 

2.36 

17.1 

14.1 

13.6 

11.6 

Lincoln 

0.45 

0.40 

0.33 

0.31 

3.4 

2.5 

2.2 

1.6 

Linn 

1.77 

1.39 

1.37 

1.30 

9.4 

8.2 

8.5 

7.1 

Marion 

0.62 

0.43 

0.39 

0.36 

2.6 

2.0 

2.0 

1.7 

Multnomah 

0.13 

0.09 

0.08 

0.08 

0.5 

0.4 

0.4 

0.4 

Polk 

3.91 

2.75 

2.43 

2.41 

16.2 

13.6 

13.1 

12.2 

Tillamook 

1.38 

1.14 

1.03 

0.93 

8.2 

7.7 

6.4 

8.7 

Washington 

0.19 

0.13 

0.11 

0.10 

0.8 

0.6 

0.6 

0.5 

Yamhill 

1.09 

0.75 

0.67 

0.64 

4.9 

3.7 

3.6 

3.1 

Average 


$3.01 


$2.19 


$2.54 


$1.81 


13.6 


10.9 


10.9 


9.5 


'  Represents  county  O&C  distribution  for  fiscal  year  (ending  September  30)  divided  by  total  assessed  value  (in  thousands)  on  January  1  of  same 

calendar  year. 

2  Represents  O&C  distribution  as  percent  of  total  property  tax  levy  for  following  year,  e.g.,  FY  1977  distribution  as  percent  of  1977-78  levy. 

Source:  USDI.  BLM  1979a  and  1980e.  BLM  Facts-Oregon  and  Washington,  1979,  1980;  Oregon  Dept  of  Revenue,  Oregon  Property  Tax  Statistics, 
1978;  Oregon  Dept.  of  Revenue,  Dick  Yates,  telephone  conversations,  April  15,  1980,  June  24.  1980;  Oregon  Department  of  Revenue,  Vinh  Ninh, 
telephone  conversation,  April  13.  1981. 


Table  2-21  In-Lieu  Tax  Payment  on  CBWR  Lands  Administered  by  the 

BLM  in  Douglas 

County1 

Average  Annual 

Average  CBWR 
Disbursements 

Average  Annual 

Property  Tax 

Average  Budget  Levy 

(1979-1981) as  a 

Severance  Tax  Re- 

Received3 

Submitted  By  Each  Tax 

Percent  of  Aver- 

Tax District 

ceived2  (1979-1981) 

(1977-1981) 

District  (1979-1981) 

age  Levy  (1979-1981) 

Douglas  County 

$  2,929 

$    665 

$2,078,000 

0.2% 

Oakland  School 

District  I 

207 

68 

1,230,000 

•  0.1% 

Camas  Valley  School 

District  21 

9,091 

2,983 

415,000 

2.9% 

Winston  Dillard  School 

District  116 

23,575 

5,850 

3,018,000 

1 .0% 

Douglas  Education 

Service  District 

2,235 

622 

2,740,000 

0.1% 

Umpqua  Community 

College 

2,295 

783 

1,951,000 

0.2% 

Roseburg  School 

District  4 

04 

24 

7,949,000 

<0.1% 

'  Payments  in-lieu  of  taxes  are  made  to  the  county  treasurer 

and  distributed  to  tax  districts. 

2  Severance  tax  is  6-1/2  percent  of  the  value  of  the  timber  harvested. 

3  Assessed  value  of  forest  land  is  a  function  of  the  price  of  second-growth  Douglas- 

ir  stumpage  over  the  most  recent  three-year  period 

4  The  27  acres  of  CBWR  lands  ir 

i  this  school  district  are  not  forested  with  commerical  species. 

Source:  Douglas  County  Assessor,  Douglas  County  Treasu 

rer. 

53 


accordance  with  timber  assessed  values  on  CBWR 
lands  prior  to  the  institution  of  the  severance  tax. 
In-lieu  property  taxes  are  calculated  at  levy  rates 
on  the  assessed  value  of  land  only.  Table  2-21 
shows  the  historical  distribution  of  these  payments 
in  Douglas  County. 

A  net  of  4  percent  of  revenues  from  public  domain 
lands  is  remitted  to  state  governments.  These 
revenues  in  Oregon  are  distributed  to  counties  on 
the  basis  of  total  land  areas  for  the  benefit  of 
county  roads  and  bridges.  Receipts  from  the  sale 
of  timber  on  public  domain  lands  in  the  Roseburg 
District  were  $902,700  in  FY  1980  and  $461,700  in 
FY  1981.  These  receipts  yielded  $36,100  to  Oregon 
counties  in  FY  1980  and  $18,500  in  FY  1981. 

Timber  Industry 

Approximately  one  out  of  every  four  workers 
in  Douglas  County  harvests,  processes  or 
transports  some  type  of  wood  product  (ratio  of 
lumber  and  wood  products  employment  to  total 
employment,  see  Table  2-17).  For  the  region,  one 
out  of  every  seven  workers  is  actively  engaged  in 
the  flow  of  wood  products.  In  contrast,  for  all 
Oregon  workers,  only  one  in  every  14  is  employed 
in  the  wood  products  industry. 

During  1977-78,  40  percent  of  all  wages  paid  in 
Douglas  County  (in  sectors  covered  by  State  and 
federal  employment  insurance  programs) 
originated  in  the  wood  products  sector.  For  the 
region,  the  same  figure  is  27  percent  and  for 
Oregon,  12  percent. 

The  Roseburg  District  plays  a  significant  role  in 
providing  raw  material  to  the  lumber  and  wood 
products  sector.  For  example,  during  the  1976- 
1977  period,  13.5  percent  of  the  Douglas  County 
harvest  came  from  the  Roseburg  District  (Table  2- 
22).  BLM's  Medford,  Coos  and  Eugene  Districts 
also  administer  land  in  Douglas  County. 

Table  2-22  Timber  Harvest  (MM 
bd.  ft.  Scribner  long  log  volume)  by 
Ownership  Class,  Douglas  County 


1976 
1977 


All 
Ownerships 

1.308.3 
1.269.1 


BLM 


3439 
2995 


Roseburg 
District 

199.7 
1476 


Source:  Oregon  Department  of  Forestry  and  Roseburg  District 

Historical  data  underscore  the  role  of  BLM 
stumpage  in  log  processing  within  Douglas 
County.  These  data  show  that  sawmill  and 
plywood  and  veneer  facilities  in  the  county  have 
become  increasingly  dependent  on  BLM  timber. 
Conversely,  processors  statewide  are  looking  less 
and  less  to  Bureau  lands  for  log  supply  (Table 
2-23). 


The  timber  management  program  on  the  Roseburg 
District  affects  the  regional  economy  employment 
and  personal  earnings  in  three  ways:  1)  the  harvest 
and  processing  of  the  timber;  2)  site  preparation, 
replanting  and  subsequent  management  of 
harvested  units;  and  3)  the  disbursement  of  O&C 
revenues. 

The  economic  effects  of  timber  harvest, 
processing,  reforestation,  intensive  management 
and  O&C  disbursements  to  counties  in  the  region 
stem  from  the  average  annual  harvest  and  the 
value  of  the  sale  units  harvested.  During  the  1976- 
1980  period,  harvest  of  BLM  timber  in  the 
Roseburg  District  averaged  187.5  MM  bd.  ft.  and 
the  typical  unit  yielded  $157  per  M  bd.  ft.  (Table  2- 
24).  This  average  annual  harvest  and  value  of 
receipts  supported  more  than  3,200  jobs  in  the 
region,  including  over  2,400  jobs  in  Douglas 
County.  The  payrolls  associated  with  this 
employment  equaled  $32  million  in  Douglas 
County  and  $50.1  million  in  the  region  (Table 
2-25). 

Fishing,  Hunting  and  Other 
Recreation 

The  annual  economic  effects  of  expenditures 
made  by  persons  engaged  in  commercial  and 
sport  fishing,  hunting  and  general  recreation  are 
listed  in  Table  2-26.  In  total,  the  production  of 
these  three  resource  categories  on  Roseburg 
District  BLM-administered  lands  generates  the 
equivalent  of  109  full-time  jobs  and  $568,000  in 
local  personal  income  each  year. 

Social  Concerns 

Timber,  as  the  main  economic  support  of  the 
local  economy,  greatly  influences  social  attitudes 
and  concerns  of  residents.  Individual  economic 
welfare  is  often  closely  related  to  the  welfare  of  the 
timber  industry.  The  current  depression  in  the 
local  economy  has  raised  concern  about  the 
timber  industry. 

The  fluctuations  of  the  industry  have  required 
people  to  adjust  to  changes  in  their  welfare.  For 
example,  Figure  2-4  shows  the  expansions  and 
contractions  which  took  place  in  the  lumber  and 
wood  products  sector  in  Douglas  County  between 
1970-1980.  While  the  average  level  of  employment 
for  the  decade  was  8,565,  the  average  annual  level 
of  wage  and  salary  workers  ranged  from  a  high  of 
9,150  in  1973  to  a  low  of  7,600  in  1980. 
Furthermore,  forecasts  of  a  dwindling  timber 
supply  (Beuter  et  al.  1976,  Stere  et  al.  1980,  Rahm 
1980,  U.S.  Forest  Service  1980)  in  the  Pacific 
Northwest  and  projections  of  declining  lumber  and 
wood  products  employment  (Bruner  and 
Hagenstein  1981)  in  one  or  two  decades  are  likely 
to  increase  concern  about  the  timber  supply. 


54 


Table  2-23  Dependency  of  Log  Processors  in  Oregon  and  Douglas  County 
on  BLM  Timber  (All  processing  estimates  in  M  bd.  ft.) 

Origin  of  logs  consumed  by  sawmills  in  Oregon  by 
19763 

ownership  class  19681, 19722  and 

All  Ownerships 

BLM 

%  BLM  of  Total 
Processed 

1968 
1972 
1976 

Douglas 
Douglas 
Douglas 

532,340 
632,863 
519,915 

167,408 
233,868 
222,236 

31.4 
37.0 
42.7 

1968 

1972 
1976 

Oregon 
Oregon 
Oregon 

5,863,324 
6,140,629 
5,404,346 

740,227 
801,034 
642,920 

12.6 
13.0 
11.9 

Origin  of  logs  consumed 
and  county 
1968\19722and19763 

by  plywood  and  veneer  m 

ills  in  Oregon  by  ownership  class 

1968 
1972 
1976 

Douglas 
Douglas 
Douglas 

591,560 
565,466 
599,983 

183,707 
268,500 
252,010 

31.1 
47.6 
42.0 

1968 
1972 
1976 

Oregon 
Oregon 
Oregon 

3,578,494 
3,650,016 
3,305,705 

655,670 
714,334 
584,241 

18.3 
19.6 
17.7 

1  Manack,  Eugene  R.,  Choate,  Grover  A.,  i 
State  of  Oregon  Dept.  of  Forestry. 
*  Schuldt,  John  P.,  and  James  0.  Howard, 
427,  Dec.  1974,  113  p. 
Howard,  James  0..  and  Hiserote,  Bruce 

nd  Gedney.  Donald  R.,  Oregon  Timber  Industries:  Wood  Consumption  and  Mill  Characteristics  1968. 
Oregon  Forest  Industries,  1972  Wood  Consumption  and  Mill  Characteristics,  OSU  Special  Report  No 
\.,  Oregon's  Forest  Products  Industry  1976,  USDA  Forest  Service  Resource  Bulletin  PNW-79.  1978. 

Table  2-24  Harvest  Sales  and  Receipts,  BLM  Timber  in  the  Roseburg 
District  (FY  1976-1980) 


Fiscal 

Sale 

Removals 

Value  of  Sales 

Value  of  Receipts 

Year 

(MM  bd.  ft.) 

(MM  bd.  ft.) 

($1,000,000) 

($1,000,000) 

1976 

232.3 

165.6 

35.0 

20.9 

Transition  Quarter 

49.6 

82.8 

6.5 

13.7 

1977 

188.8 

212.2 

29.1 

39.2 

1978 

185.7 

198.3 

30.4 

27.9 

1979 

188.1 

169.9 

45.5 

27.2 

1980 

190.5 

155.4 

56.9 

26.1 

Average  12  month  harvest,  1976-1980:  187.5  MM  bd.  ft. 
Average  value  per  M  bd.  ft.  removed:  $157 


55 


Douglas 
County 

Regional 
Economy 

187.5 

187.5 

1,106 

1,388 

$15.8 

$20.3 

1,106 

1,331 

4,300 

4,300 

38 

38 

$0.3 

$0.3 

19 

19 

Table  2-25  Average  Annual  Local  Economic  Effects  of  Timber 
Management  on  Lands  Administered  by  the  Roseburg  District  (1976-1980) 

Total  for 


Average  Harvest  Volume  (MM  bd.  ft.  Scribner  Short  Log  Rule)  1976-1980 

Number  of  Local  Jobs  Provided  by  Harvesting  and  Processing  1 

Annual  Local  Payroll  Generated  by  Harvesting  and  Processing  ($1,000,000) 

Number  of  Local  Jobs  Produced  in  Other  Business  Sectors  Resulting  from 
Payrolls  Created  by  Harvesting  and  Processing' 

Annual  Local  Payroll  in  Other  Business  Sectors  Created  by  Harvesting  and  $10.4  $13.8 

Processing  ($1,000,000)2 

Acres  Harvested  Each  Year 

Number  of  Local  Jobs  in  Reforestation  and  Intensive  Management  1 

Annual  Local  Payroll  in  Reforestation  and  Intensive  Management  ($1,000,000)2 

Number  of  Local  Jobs  Produced  in  Other  Business  Sectors  Because  of 
Reforestation  and  Intensive  Management  on  Lands  Administered  by  the  Roseburg 
District1 

Annual  Local  Payroll  Produced  in  Other  Business  Sectors  Because  of  $  0.1  $  0.1 

Reforestation  and  Intensive  Management  on  Lands  Administered  by  the  Roseburg 
District  ($1,000,000)2 

Public  Revenue  to  County  Governments  Attributable  to  the  Harvest  ($1,000,000  $  3.7  $10.9 

in  O&C  Disbursements) 

Number  of  Employees  of  County  Government  Whose  Jobs  Depend  Upon  Public  73  214 

Revenues  from  the  Sale  of  BLM  Timber  Obtained  from  Lands  Administered  by  the 
Roseburg  District 

Annual  Payroll  of  County  Government  Employees  Whose  Jobs  Depend  Upon  $0.8  $2.2 

Public  Revenue  from  the  Sale  of  BLM  Timber  Obtained  from  Lands  Administered 
by  the  Roseburg  District  ($1,000,000)2 

Number  of  Local  Jobs  Produced  in  Other  Business  Sectors  Because  of  County  79  232 

Employment  Dependent  on  O&C  Disbursements  and  the  Jobs  Created  by 
Disbursements  Passed  Through  to  the  Local  Economy  in  the  Form  of  Capital 
Construction  or  County  Support  of  Local  Programs 

Annual  Payrolls  in  Other  Business  Sectors  Dependent  on  County  Payrolls  $0.9  $2.5 

Created  By  Disbursements  Passed  Through  to  the  Local  Economy  in  the  Form  of 
Capital  Construction  or  County  Support  of  Local  Programs  ($1,000,000)2 

Total  Local  Employment  Effect  of  the  Timber  Management  Program1 

Local  employment  effect  per  MM  bd.  ft.  of  BLM  timber  harvested 

Local  earnings  per  MM  bd.  ft  of  BLM  timber  harvested 

Total  Local  Payroll  Effect  of  the  Timber  Management  Program 
($1,000,000)2 

'  All  estimates  refer  to  full-time  employment,  e.g.,  two  jobs  of  6-month  duration  equal  one  full-time  equivalent. 
•'1976-  1978  dollars. 


2,421 

3,222 

12.9 

17.2 

$150,900 

$209,100 

$28.3 

$39.2 

56 


Table  2-26  Local  Economic  Effects 
of  Fisheries,  Terrestrial  Wildlife  and 
General  Recreation 

Employment 

Earnings' 

Fisheries 

Direct 
Indirect 

25 
10 

130.000 
76,000 

Hunting 

Direct 
Indirect 

15 
6 

64,000 
36,000 

Other  Recreation 

Direct 
Indirect 

38 
15 

163,000 
99,000 

Total 

109 

568,000 

1  1976-1978  dollars 

The  seasonal  variations  in  timber  industry  and  the 
longer  fluctuations  in  employment  attributable  to 
market  conditions  have  produced  a  kind  of  dual 
work  force  in  the  industry  consisting  of  a  core  of 
stable,  senior  workers  and  a  peripheral  group  of 
workers  who  "float"  in  and  out  of  the  industry  in 
response  to  the  job  situation  or  higher  pay 
(Stevens  1978). 

Herbicide  use  is  a  controversial  issue  having  many 
vocal  advocates  and  opponents.  Advocates  believe 
it  is  an  inexpensive  and  safe  means  of  increasing 
timber  production  by  controlling  competing 
vegetation  when  used  with  proper  safeguards. 
Opponents  believe  further  evidence  is  needed  to 
prove  that  herbicide  use  is  less  expensive  than 
other  means.  They  also  believe  herbicide  use  may 
be  damaging  to  the  environment  and  harmful  to 
human  health. 

Also  controversial  with  some  adjoining  landowners 
and  other  residents  are  clearcutting  and 
anticipated  damage  to  watersheds  from  harvesting 
timber  on  steep  slopes. 


FIGURE  2-4 


CO 

UJ 

LlJ 

>- 

o 


Annual  Average  Lumber  and  Wood  Products  Employment 
Douglas  County,  Oregon   1 970 -1 980 


10,000 


9000 


8000 


£     7000 
rr 

UJ 
GO 

2     6000 

3 


0 


1970 


71 


72 


73 


74 


75  76 

YEAR 


77 


78 


79 


80 


57 


Table  2-27  Changes  Desired  by  Survey  Respondents  in  the  Use  of  Federal 

Lands 

(Percent  distribution  omitting  undecided  respondents) 


Oregon 


Southern  Oregon 


No 

No 

Use 

More 

Change 

Less 

More 

Change 

Less 

Wildlife  habitat 

61 

30 

8 

49 

36 

14 

Hiking/Camping 

52 

38 

8 

40 

46 

12 

Wilderness 

44 

38 

16 

32 

28 

39 

ORVs/snowmobiles 

13 

24 

60 

19 

33 

44 

Timber  Production 

41 

38 

19 

60 

26 

13 

Hunting/Fishing 

51 

40 

7 

53 

42 

4 

Source:  Tiff  Harris,  Public  Perceptions  of  Federal  Land  Use  Decisionmaking  in  Oregon:  Results  of  a  State-wide  Survey,  Oregon  State  University. 
August  1979 

A  recent  statewide  survey  by  Bardsley  and 
Haslacher  (Harris  1979)  showed  that  residents  of 
southern  Oregon  (including  Douglas  County)  have 
different  attitudes  about  the  use  of  federal  lands 
than  do  Oregonians  in  general.  These  survey 
results  are  shown  in  Table  2-27. 

Local  Employment  and 
Personal  Earnings  Attributable 
to  Resources  Produced  by 
BLM-Administered  Land 

In  summary,  the  principal  sources  of  local 
employment  and  personal  earnings  attributable  to 
resources  produced  on  BLM-administered  land  in 
the  Roseburg  District  are: 

Resource  Employment    Earnings 

Timber  3,222         $39,200,000 

Commercial  and  Sport 
Fisheries 

Hunting 

Other  Recreation 


35 


206,000 


21  100,000 

53  262,000 

3,331         $39,768,000 


59 


Chapter  3  Environmental 
Consequences 


Introduction 


In  this  chapter,  environmental  consequences 
(impacts)  are  compared  to  the  existing  situation, 
as  described  in  Chapter  2.  Economic  impacts  are 
based  on  the  existing  situation  plus  projections  of 
price  and  revenue  levels  under  Alternative  5  (No 
Action).  The  significant  impacts  resulting  from 
implementation  of  each  of  the  alternatives  are 
analyzed  in  relation  to  these  baselines.  A  tabular 
comparison  of  composite  impacts  from  each 
alternative  is  shown  in  Table  1-5.  Analysis, 
including  the  scoping  process,  indicates  that 
timber  management  would  have  no  significant 
impacts  upon  climate,  geology,  topography, 
minerals,  grazing,  agriculture,  utilities, 
communication  sites  and  wilderness.  Therefore, 
these  topics  are  not  discussed. 

The  major  actions  which  cause  impacts  are  timber 
harvest,  road  construction,  site  preparation 
(includes  slash  burning  and  herbicide  use), 
plantation  maintenance  and  release,  plantation 
protection,  precommercial  thinning  and 
fertilization.  Significant  effects  to  the  local  area 
and  its  economic  base  can  also  occur,  depending 
upon  which  alternative  and  harvest  volume  levels 
are  ultimately  selected.  These  would  include 
changes  in  employment,  personal  income  and 
sharing  of  sale  receipts  with  county  governments, 
school  districts  and  other  local  taxing  entities. 


60 


In  analyzing  the  impacts  of  the  Original  Proposed 
Action  (Alternative  4),  a  sample  5-year  (1984-1988) 
timber  sale  plan  (available  for  review  at  the 
Roseburg  District  Office)  was  developed  and  used, 
where  applicable,  to  assess  potential  site  specific 
timber  sale  impacts.  Although  a  5-year  plan  is 
used  for  analysis  purposes,  actions  identified  are 
considered  typical  for  the  entire  decade.  Possible 
conflicts  identified  in  this  chapter  for  specific  sales 
will  be  thoroughly  addressed  in  detailed  site 
specific  environmental  assessments.  Timber 
management  treatments  not  included  in  the  timber 
sale  plan  (planting,  vegetation  control  with 
herbicides,  animal  damage  control,  precommercial 
thinning  and  fertilization)  are  analyzed  at  the 
proposed  10-year  levels.  Site  specific 
environmental  assessments  will  be  prepared  when 
specific  acreages  are  identified  for  each  treatment. 
Analysis  of  the  alternatives  is  based  on  the 
different  levels  of  treatments  shown  in  Table  1-2. 

Two  time  frames  are  used  in  the  analysis  process. 
The  short  term  is  the  first  10  years  following  the 
adoption  of  a  new  timber  management  plan.  The 
long  term  is  defined  as  beyond  10  years.  Other 
time  periods  pertinent  to  specific  impact 
discussions  are  used  as  necessary  and  identified 
in  the  text. 

Analysis  of  long-term  impacts  for  all  alternatives  is 
based  on  the  assumption  that  the  alternatives 
would  be  continued  for  many  decades.  In  fact,  the 
10-year  timber  management  plan  and  related  land- 
use  allocations  selected  after  completion  of  the 
EIS  will  be  subject  to  revision  at  the  end  of  one 
decade. 

A  basic  assumption  of  the  analysis  is  that 
sufficient  funding  and  personnel  will  be  available 
for  implementation  of  the  final  decision. 

Impacts  on  Air  Quality 

During  the  construction  of  new  roads  and 
maintenance  of  older  roads,  fine  particulate  matter 
would  be  disturbed.  This  dust  settles  back  to  earth 
in  relatively  short  distances,  does  not  adversely 
impact  anyone  away  from  the  construction  sites 
and  thus  will  not  be  considered  further. 

The  major  impact  to  air  quality  in  the  SYUs  would 
be  from  slash  burning.  Estimated  levels  of  burning 
activity  by  alternative  are  given  in  Table  1-2  (Site 
Preparation/Broadcast  Burning). 

Regardless  of  the  alternative  selected,  all  burning 
would  be  done  in  accordance  with  the  Oregon 
Smoke  Management  Plan.  Normally,  smoke  would 
be  carried  into  upper  air  levels  and  away  from 
populated  areas.  Occasionally,  unforecasted 
weather  changes  could  cause  some  smoke  to 
return  to  surface  areas,  causing  visible  intrusions 
in  nearby  residential  areas.  When  slash  fires  are 
allowed  to  burn  or  smolder  overnight,  the  cooling 
nighttime  temperatures  bring  residual  smoke  down 


valleys,  causing  problems  with  visibility  and 
increased  particulates.  The  probability  of  intrusion 
would  be  highest  under  Alternative  1,  due  to  more 
acres  burned,  and  lowest  under  Alternative  8.  Past 
experience  indicates  that  visible  intrusions  may 
affect  the  population  centers  of  Eugene- 
Springfield  and  Roseburg.  Reported  smoke 
intrusions  from  BLM  Roseburg  District  slash  burns 
affected  the  area  from  Roseburg  to  North  Bend  in 
1980  (OSDF  1981).  Between  1976  and  1981 
Roseburg  BLM  was  responsible  for  18  of  the  56  (32 
percent)  reported  smoke  intrusions  in  Douglas 
County.  None  of  the  intrusions  during  the  above 
period  led  to  a  violation  of  primary  air  quality 
standards  for  total  suspended  particulates  (Table 
2-1). 

Since  1980,  there  has  been  an  effort  to  shift  the 
prescribed  fire  workload  from  the  traditional  fall 
season  to  spring  and  early  summer.  It  is  estimated 
that  30  percent  of  the  prescribed  fire  workload  will 
occur  in  the  spring  and  early  summer.  This  is  the 
season  of  best  smoke  dispersion  opportunities.  In 
the  spring,  larger  fuels  and  the  duff  have  fuel 
moistures  too  high  to  sustain  fire.  This  results  in 
less  volume  consumed  and  a  corresponding 
reduced  volume  of  smoke.  Climatic  conditions  in 
the  spring  also  increase  the  efficiencies  of 
prescribed  fire  mop-up  activities,  resulting  in  less 
residual  smoke.  The  trend  in  increasing  wood 
utilization  is  also  contributing  to  less  volumes  of 
slash  occurring  on  harvested  areas.  These 
emission  reduction  techniques  contribute  to  an 
estimated  35  percent  decrease  in  volume  of  smoke 
produced  per  acre  burned  (Sandberg  1983).  This 
data  does  not  allow  a  statistically  correct 
projection  of  expected  problems  over  the  next 
decade. 

Airborne  particles  less  than  1.0  micron  in  diameter 
make  up  80  percent  of  smoke  particulates. 
Particles  of  this  size  have  very  low  fall  velocities, 
about  5  cm/hour,  and  therefore  will  travel 
distances  of  approximately  100  miles.  Particles  of 
this  size  also  scatter  visible  light  (0.3  microns  blue 
to  0.8  microns  red),  causing  visibility  problems. 

Depending  on  the  wind  direction  and  speed 
following  slash  fires,  visibility  intrusions  could 
occur  in  the  Eugene-Springfield  AQMA,  the 
Roseburg  AQMA,  and  in  the  following  Class  I 
areas:  Kalmiopsis,  Crater  Lake,  Mt.  Washington, 
Three  Sisters,  Mt.  Jefferson  and  Diamond  Peak. 

The  wood  component  of  slash  is  made  up  of  about 
50  percent  carbon,  6  percent  hydrogen,  43  percent 
oxygen  and  small  amounts  of  nitrogen  and  other 
elements.  When  burning  occurs,  temperatures  of 
570°  F  to  2550°  are  maintained  (Hall  1972)  which 
produce  carbon  dioxide  and  water  vapor.  The 
whitish  column  of  smoke  observed  from  controlled 
slash  fires  is  made  up  of  over  90  percent  water 
vapor  and  C02  (Table  3-1 ). 


61 


Table  3-1  Avi 


verage  Emission  Components  From  Slash  Burning  (Tons/Decade) 


ALTERNATIV 


1 

2 

3 

4 

5 

6 

7 

8 

9 

Max.  Tbr. 

Emp.  Tbr. 

LoMHS 

OPA 

No  Action 

HD 

No  Herb. 

Full  Eco. 

NPA 

Tons  of  Slash 

182,308 

167,654 

161,487 

157,105 

120,922 

115,472 

108,269 

54,369 

155,826 

Burned 

Particulates' 

3.828 

3,521 

3,391 

3,299 

2,539 

2,425 

2,274 

1,142 

3,273 

Hydrocarbons 

2,279 

2,096 

2,019 

1,964 

1,512 

1,443 

1,353 

680 

1.948 

Carbon  Monoxide' 

23,700 

21,795 

20,993 

20,424 

15,720 

15,011 

14,075 

7,068 

20,262 

Sulfur  Oxides4 

Negl 

igible  

Nitrous  Oxides5 

365 

335 

323 

314 

242 

231 

217 

109 

312 

Water  Vapor  and 

Carbon  Dioxide6 

90% 

of  the  Mass  of  Combustion  Products  - 

'  Particulates  are  near  0.1  micrometer  in  diameter.  Average  emission  of  17-67  pounds/ton  slash  burned. 

2  Hydrocarbons  are  a  diverse  class  of  compounds  containing  hydrogen,  carbon  and  oxygen. 

3  Carbon  monoxide  (CO)  is  very  short  lived  in  the  natural  environment  and  quickly  dilutes  and  also  converts  to  C02. 

4  Sulfur  oxides  (SOx)  are  produced  in  small  quantities,  since  most  forest  residues  contain  less  than  0.2  percent  sulfur 

5  Nitrogen  oxides  (NOx)  are  found  in  some  very  hot  fires,  but  this  is  generally  not  a  problem  in  prescribed  burns.  The  temperature 
required  to  fix  atmospheric  nitrogen  is  over  2800°  F  and  such  a  temperature  is  not  frequently  attained  in  slash  burns. 

6  Carbon  Dioxide  (CO,)  is  not  an  air  pollutant  in  the  usual  sense.  About  1  ton  of  burned  fuel  produces  1  to  1-1/2  tons  of  C02  (Ryan  et 
al.  1976,  cited  in  Sandberg  et  al.  1978). 


Source:  J  Alfred  Hall  1972  and  Sandberg  et  al.  1978 

The  contaminants  most  frequently  found  in  slash 
smoke  are  carbon  dioxide  (C02),  carbon  monoxide 
(CO),  nitrogen  oxides  (NOx),  hydrocarbons  (HC) 
and  respirable  fine  particulates  (Sandberg  et  al. 
1978). 

Conclusions 

The  major  impact  to  air  quality  would  be 
visible  smoke  from  slash  burning.  Although 
occasional  smoke  intrusions  are  likely,  none  are 
expected  to  violate  primary  air  quality  standards 
for  total  suspended  particulates. 

Impacts  on  Soils 

The  major  impacts  of  timber  management  on 
soils  are  compaction,  landsliding,  topsoil  erosion 
and  depletion  of  organic  matter,  nitrogen  and 
other  nutrients.  Each  results  in  a  loss  of  soil 
productivity  (see  Glossary).  Timber  management 
activities  that  are  the  causal  agents  include  road, 
fire  trail  and  landing  construction;  yarding  logs; 
scarification  and  slash  burning.  The  amount  of 
landslides  and  surface  erosion  is  influenced  by  the 
steepness  of  slopes,  soil  properties,  amount  of 
disturbance  and  remaining  litter  cover,  and  the 
amount  and  intensity  of  precipitation  (Pritchett 
1979). 

Standard  design  features  would  be  employed  to 
minimize  adverse  impacts  on  soils.  Compacted 
soils  from  tractor  logging  in  clearcut  units  would 
be  ripped  or  tilled  to  partially  restore  productivity. 
Loss  of  productivity  due  to  compaction  from 
tractor  logging  in  partial  cut  units  cannot  be 
mitigated  during  the  rest  of  the  rotation.  Partial 
and  total  suspension  yarding  systems  would  be 
used  to  minimize  soil  disturbance.  New  roads 
would  be  located  away  from  streams  and  on 


ridgetops  and  designed  to  avoid  undercutting  or 
overloading  unstable  slopes.  Excess  road  material 
on  unstable  and  potentially  unstable  slopes  would 
be  end-hauled  to  reduce  landsliding.  Scarification 
would  be  done  during  dry  soil  conditions  without 
piling  soil.  Slash  burning  and  scarification  would 
be  minimized  on  thin,  droughty  or  nitrogen- 
deficient  soils. 

Table  3-2  shows  estimated  acres  upon  which  soil 
productivity  would  be  lost  as  a  result  of  timber 
management  under  the  proposed  action  and 
alternatives  during  the  first  decade. 

Soil  compaction  results  primarily  from  the  weight 
and  shearing  forces  involved  in  dragging  logs  and 
operating  ground-based  logging  equipment. 
Compaction  hinders  root  penetration  and  water 
percolation  and  availability,  reducing  vegetation 
growth.  Decreases  in  root  penetration  of  35  to  65 
percent  can  reduce  the  vegetative  productivity  of 
soils  by  10  to  25  percent  (Power  1981a).  In  the 
Roseburg  SYUs,  tractor  logging  has  been  found  to 
reduce  soil  productivity  for  the  entire  cutting  unit 
by  11.8  percent  due  to  compaction  (Wert  and 
Thomas  1981).  Yarding  systems  using  ground- 
based  equipment  have  a  greater  adverse  impact  on 
soils  than  cable  systems  which  drag  the  logs.  One 
end  suspension  has  a  lesser  impact  than  systems 
providing  no  suspension.  Systems  using  total 
suspension  have  the  least  impact  on  soils. 
Compaction  and  reduced  infiltration  capacity  have 
been  found  to  last  at  least  55  years  (Power  1974, 
cited  in  Fredriksen  and  Harr  1979)  and  therefore 
may  last  longer  than  harvest  rotation  periods. 

Site  scarification  and  slash  piling  by  tractors  with 
brush  rakes  compacts  soils  and  displaces  topsoil. 
This  practice  can  be  expected  to  reduce  soil 


62 


Table  3-2  Estimated  Loss  of  Productivity  During  First  Decade  (acres)1 


Process 

Road 
Construction2 

Yarding  Systems 
(Compaction)3 

Landsliding  from 
Fragile  Soils 

Dry  Ravelling 

Nutrient  Depletion 

Totals 


Alt.  1         Alt.  2        Alt.  3        Alt.  4        Alt.  5        Alt.  6        Alt.  7        Alt.  8        Alt.  9 

Max.        Emp.  Lo  No  No  Full 

Tbr.         Tbr.         MHS        OPA       Action        HD         Herb.        Eco.         NPA 


5,568        5,124        4,932        4,800        3,696        3,528        3,306        1,662        4,780 


3,551         3,267        3,135        3,057       3,132         2,250        2,131  980        3,056 


11 


10 


17  16  15  15 

Acreage  data  unavailable 
Acreage  data  unavailable  (see  Table  3-3) 
9,136        8,407        8,082        7,872        6,839        5,788 


10 


15 


5,447   2,647    7,851 


'  Productivity  loss  of  commercial  timber  resulting  from  road  construction  and  landslides  is  long  term.  Loss  from  compaction  has  been 
estimated  to  last  up  to  55  years  on  some  soils. 

2  From  Table  1-2. 

3  These  are  equivalent  net  acres  (acres  compacted  x  percent  loss  of  productivity  due  to  compaction)  assuming  amelioration  by 
ripping. 


productivity  by  11  to  22  percent  (Clutter  and  Dell 
1978).  One  study  in  the  Salem  District  showed  a 
reduction  of  17  percent  in  productivity  after 
scarification  (Power  1981b).  Topsoil  is  also 
removed  by  dragging  logs  and  by  constructing  fire 
trails,  roads  and  landings  with  heavy  equipment. 
On  clearcuts  yarded  by  tractors,  predesignated 
skid  roads  will  be  used  so  that  less  than  10  percent 
of  the  surface  area  will  be  traversed. 

On  very  steep  slopes  with  decomposing  granitic 
bedrock,  clearcutting  increases  the  number  and 
magnitude  of  debris  avalanches  and  torrents.  This 
increase  is  caused  by  decay  of  small  tree  roots,  log 
gouges  from  yarding,  plugged  road  culverts  and 
road  construction  and  usually  occurs  1  to  3  years 
after  harvesting  (Hughes  and  Edwards  1978).  The 
5-year  timber  sale  plan  shows  825  acres  of  soils 
from  granitics  would  be  subjected  to  timber 
harvest. 

Erosion  from  landslides  in  Tyee  sandstone,  as 
measured  in  the  Mapleton  Ranger  District 
(Swanson,  Swanson  and  Woods  1977),  increases 
123  times  above  the  undisturbed  forest  rate 
following  clearcutting  and  roadbuilding. 
Approximately  4,600  acres  of  these  soils,  identified 
as  fragile,  would  be  harvested  as  shown  in  the 
sample  5-year  timber  sale  plan. 

Estimates  of  acres  of  soil  lost  due  to  landsliding 
are  given  in  Table  3-2.  The  size  of  potential 
landslides  ranges  from  20  to  250  feet  wide  and  200 
to  6,000  feet  long.  Material  from  such  slope 
failures  usually  scour  stream  channels  to  bedrock, 
ending  in  debris  dams. 


Dry  ravelling  in  disturbed  areas  takes  place 
throughout  the  year  in  the  SYUs  and  results  in  loss 
of  topsoil  and  decreased  soil  depth.  When 
vegetation  and  duff  are  removed  by  yarding  logs, 
slash  burning  or  other  practices,  surface  soil  is 
free  to  move  and  ravelling  is  accelerated.  On 
steep,  south-facing  slopes  ravelling  may  continue 
for  20  to  30  years  after  disturbance  or  until 
vegetation  becomes  reestablished. 

Nitrogen  (N)  in  forest  soils  is  largely  in  the  humus 
layer.  Amounts  of  2  to  10  tons  per  acre  can  be 
found  in  deep  silt  loams  under  old  growth 
Douglas-fir  (Heilman  1981).  Much  of  this  N  in  the 
slash  and  litter  is  volatilized  during  slash  burning 
and  is  lost.  Total  loss  of  N  from  clearcutting  and 
slash  burning  can  reach  as  high  as  9  percent  of 
available  N  (Hornbeck  et  al.  1974,  in  Sopper  1975), 
but  more  likely  will  be  about  4  percent  (Grier 
1982).  Losses  of  phosphorus  (P)  are  similar  to 

Table  3-3  Expected  Nutrient  Losses 
(Tons)  from  Timber  Harvesting  and 
Slash  Burning  (10-Year  Plan) 


Alternative 

N 

P 

K 

Ca 

1  (Max   Tbr  ) 

3.076 

3.691 

344 

850 

?  (Emp  Tbr) 

2,829 

3,394 

316 

782 

3  (Lo  MHS) 

2.725 

3.269 

305 

753 

4  (OPA) 

2.651 

3.181 

296 

733 

5  (No  Action) 

2.040 

2  448 

228 

564 

6(HD) 

1.949 

2.338 

218 

538 

7  (No  Herb  ) 

1.827 

2.192 

204 

505 

Eco.) 

917 

1.101 

103 

254 

9  (NPA) 

2,640 

3.170 

295 

731 

Source:  Based  on  analysis  of  a  35-year-old.  second  growth 
Douglas-fir  ecosystem. 


63 


losses  of  N.  Losses  of  nutrients  calcium  (Ca)  and 
potassium  (K)  are  a  little  less  than  N  and  P 
(Fredriksen  1972;  Grier,  personal  communication). 
These  nutrients  are  attached  to  organic  detritus 
and  soil  particles  and  are  lost  as  the  soil  erodes. 
Assuming  a  4  percent  loss  of  N  and  P,  and  a  3 
percent  loss  of  Ca  and  K  following  clearcutting 
and  burning  (site  preparation),  each  alternative 
would  result  in  losses  shown  in  Table  3-3. 

Conclusions 

Impacts  to  soil  and  soil  productivity  are 
mainly  due  to  road  construction,  landslides,  and 
compaction.  Alternative  1  has  the  greatest  impacts 
on  long-  and  short-term  soil  productivity  while 
Alternative  8  has  the  least.  Acres  lost  from 
production  range  from  2,647  under  Alternative  8  to 
9,136  under  Alternative  1.  Less  signifcant  impacts 
include  nutrient  losses,  dry  ravelling,  and  topsoil 
removal. 

Impacts  on  Water 
Resources 

Forest  management  activities  which  would 
impact  water  resources  include  road  building, 
timber  harvest,  slash  burning  and  application  of 
fertilizers  and  herbicides.  These  activities  can 
affect  water  yields,  seasonal  streamflow 
characteristics  (peaks  and  low  flows)  and  instream 
water  quality  (sedimentation,  temperature, 
dissolved  oxygen,  nutrients  and  organic 
substances).  The  significance  of  each  impact 
would  depend  upon  the  amount  of  timber 
harvested  in  each  watershed,  the  proximity  of  the 
activities  to  streams  and  the  site  specific 
application  of  mitigating  measures. 


Water  Quantity 


Forest  harvest  activities  would  have  very 
little  effect  on  the  streamflow  of  larger  rivers 
draining  the  SYUs.  Table  3-4  shows  estimates  of 
annual  water  yield  from  public  lands  in  the  SYUs 
for  each  alternative,  compared  to  the  existing  yield 
and  undisturbed  watershed. 

Although  the  effect  of  timber  harvest  on 
streamflow  in  the  larger  rivers  would  be  small, 
local  increases  in  water  yield  would  occur  in 
clearcut  areas.  Removing  forest  vegetation 
reduces  evapo-transpiration  (see  Glossary), 
thereby  increasing  the  amount  of  rainfall  available 
for  streamflow.  Studies  of  clearcutting  small 
watersheds  in  western  Oregon  showed  that  water 
yields  from  clearcut  areas  increased  26  to  43 
percent  following  harvest  (Harris  1977;  Rothacher 
1970;  Harr  et  al.  1979).  Based  on  Rothacher's 
(1970)  study  of  clearcutting  in  the  central  Oregon 
Cascades,  water  yield  from  clearcut  areas  in  the 
SYUs  is  expected  to  increase  35  percent.  The 
duration  of  increased  water  yields  is  not  easily 
predicted;  however,  varying  degrees  of  altered 
yields  may  last  up  to  35  years  (Kovner  1956,  cited 


Table  3-4 

Estimated 

Annual  Water 

Yield  From  BLM- Administered  Land, 

End  of  First  Decade 

Percent 

Percent 

Annual 

Change 

Change 

Water  Yield 

From 

From 

Situation 

(acre-feet) 

Existing 

Undisturbed 

Past  Decade 

863,000 

0 

44 

Alt.  1  (Max.  Tbr.) 

879.000 

1.8 

63 

Alt.  2  (Emp.  Tbr.) 

875.000 

1.3 

5.8 

Alt.  3(LoMHS) 

873.000 

1.1 

56 

Alt.  4  (OPA) 

872,000 

1.0 

5.4 

Alt.  5  (No  Action) 

864,000 

0.1 

46 

Alt.  6(HD) 

860,000 

-0.4 

4.0 

Alt.  7  (No  Herb.) 

858,000 

-0.6 

38 

Alt.  8  (Full  Eco.) 

841.000 

-2.5 

1.8 

Alt.  9  (NPA) 

871.000 

0.9 

5.3 

Source:   Based   on 

analysis  of  a  35 

-year-old, 

second   growth 

Douglas-fir  ecosystem. 

in  Harr  et  al.  1979).  Compacted  soils  and  roads 
which  increase  surface  water  runoff  are  permanent 
sources  of  water  yield  increases. 

In  addition  to  altering  total  annual  water  yields, 
timber  harvest  would  affect  the  timing  and 
magnitude  of  seasonal  streamflows  in  small 
watersheds  in  the  SYUs.  Rothacher's  (1970,  1973) 
study  of  small  watersheds  near  the  SYUs  showed 
fall  and  spring  peak  flows  were  increased  by 
logging,  although  extreme  winter  peaks  were 
relatively  unaffected.  A  recent  analysis  (Christener 
1981)  suggests  that  extreme  winter  peaks  may  also 
be  increased  by  timber  harvest  if  the  peaks  occur 
from  heavy  rainfall  on  an  existing  snowpack. 
Summer  low  flow  levels  would  also  be  increased 
by  timber  harvest.  Studies  of  other  small 
watersheds  in  the  central  Oregon  Cascades 
(Rothacher  1971)  suggest  minimum  flows  for  small 
watersheds  in  the  SYUs  would  increase  up  to  300 
percent.  Although  relative  changes  in  minimum 
flows  may  be  large  (200  to  300  percent),  absolute 
changes  would  be  small,  due  to  naturally  low 
levels  of  streamflow  during  the  summer  months 
(ibid.).  Increases  in  peaks  and  low  flows  would  be 
greatest  in  small  watersheds  sustaining  the 
greatest  increases  in  clearcut  acreages  during  the 
next  decade. 


Water  Quality 


Timber  harvesting,  road  building  and  slash 
burning  would  increase  sediment  discharge  from 
affected  small  watersheds  in  the  SYUs.  Fredriksen 
and  Harr  (1979)  reported  that  logging  in  the 
central  Oregon  Cascades  increased  suspended 
sediment  yield  23  times  the  natural  rate 
(undisturbed  condition)  in  a  patch  cut  watershed 
with  roads,  and  nine  times  the  natural  rate  in  a 
clearcut  watershed  without  roads.  Hughes  and 
Edwards  (1978)  reported  that  sluice-outs  from 
intermittent  streams  in  clearcuts  were  eight  times 
as  large  (on  a  per  acre  basis)  as  from  intermittent 
streams  in  undisturbed  watersheds,  and  most  (85 


64 


percent)  resulted  from  headwall  failure.  These 
sluice-outs  originated  in  granitic  soils  (Holland- 
Siskiyou  series)  during  storms  of  5  to  12  year 
return  periods  (see  Impacts  on  Soils).  Clearcut 
acres  produced  about  530  tons/acre  of  sediment 
from  landslides  in  granitic  soils.  Similar  increases 
in  sediment  yield  can  be  expected  in  small 
watersheds  within  the  SYUs  where  mass  soil 
movement  (debris  avalanching)  is  the  dominant 
erosion  process  (see  Impacts  on  Soils).  In 
undisturbed  watersheds,  streams  are  usually 
capable  of  transporting  more  sediment  than  is 
delivered  to  them  (Rice  et  al.  1979).  During  and 
following  timber  harvest,  road  construction  and 
slash  burning,  sediment  and  debris  would  be 
delivered  to  drainage  systems.  Sediment  discharge 
would  then  no  longer  be  determined  by  the 
availability  of  sediments,  but  by  the  transporting 
ability  of  streams.  Increased  water  yields  (Table  3- 
4)  would  also  increase  the  ability  of  streams  to 
transport  sediments.  Where  stream  energy  is 
insufficient  to  transport  all  the  sediment, 
deposition  would  occur. 

Surface  vegetation  left  undisturbed  in  areas 
bordering  streams  can  act  as  a  filter  and  retain  soil 
particles  eroded  from  the  surface  of  disturbed 
areas,  thereby  reducing  suspended  sediments  in 
streams.  The  effectiveness  of  sediment  buffers  is 
dependent  upon  slope,  type  and  density  of 
vegetation  and  buffer  width.  When  water 
temperature  is  not  a  concern  and  careful  planning 
is  used  in  partial  cutting  of  buffers  (falling  timber 
away  from  streams,  no  tractor  harvest  and  no 
burning),  the  removal  of  merchantable  timber  may 
not  adversely  affect  the  sediment  trapping  ability 
of  the  buffer  (Froehlich  1982).  Buffers  would 
protect  third  order  and  larger  streams  in 
Alternatives  2  through  7  and  9,  and  protect  all 
streams  in  Alternative  8.  In  Alternative  1  no  harvest 
restrictions  are  planned  for  stream  buffers  except 
as  provided  by  the  Oregon  Forest  Practices  Act. 
When  buffers  are  left  on  third  order  and  larger 
streams,  only  sediment  produced  from  first  and 
second  order  streams  will  enter  at  the  headwaters 
and  be  carried  down  the  drainage  system 
whenever  stream  energy  is  sufficient  for  transport. 

Sediment  yield  from  surface  erosion  and  runoff 
was  estimated  by  examining  the  number  of  acres 
of  buffers  harvested  in  each  alternative  and  is 
displayed  in  Table  3-5.  The  percent  of  the  buffers 
to  be  cut  was  used  to  estimate  sediment  yield 
(Table  3-6)  and  altered  water  temperatures. 

Estimates  of  total  sediment  yield  are  presented  in 
Table  3-6. 


Table  3-5  Estimated  Sediment  Yield 
Through  Buffer  Strips 
(For  First  Decade) 


Acres  of 

Proposed 

Tons  of  Sediment 

Buffers  to  be 

From  Sheet 

Alternative 

Harvested 

Erosion 

Clearcut 

Partial  cut 

1  (Max.  Tbr.) 

N/A' 

N/A' 

303,000 

2  (Emp.  Tbr.) 

127 

1,018 

176.800 

3  (LoMHS) 

121 

981 

153,800 

4  (OPA) 

120 

960 

148,900 

5  (No  Action) 

40 

310 

164,600 

6  (HD) 

0 

0 

0 

7  (No  Herb.) 

8 

660 

102,900 

8  (Full  Eco.) 

0 

0 

0 

9(NPA) 

0 

0 

0 

1  No  harvest  restrictions  are  planned. 

The  chemical  quality  of  surface  water  would  be 
affected  by  slash  disposal.  In  one  Oregon 
Cascades  watershed  studied  by  Fredriksen  (1971), 
instream  concentrations  of  ammonia-nitrogen  and 
manganese  reached  peak  levels  of  7.6  and  0.44 
parts  per  million  (ppm),  respectively,  when  runoff 
from  rainfall  that  extingushed  the  burn  entered  the 
stream.  In  the  SYUs,  only  Alternative  8  would 
provide  adequate  protection  for  streams. 
Ammonia-nitrogen  and  manganese  concentrations 
could  exceed  recommended  water  quality 
standards  (0.02  ppm  for  free  ammonia-nitrogen, 
0.05  for  manganese)  in  some  first  and  second 
order  streams  for  several  days  following  slash 
burning.  However,  water  from  these  streams  would 
quickly  be  diluted  upon  entering  third  order  or 
larger  streams,  resulting  in  a  slight,  short-term 
impact. 

Due  to  insignificant  surface  runoff  in  areas  to  be 
fertilized,  substantial  increases  in  nutrient 
concentrations  following  forest  fertilization  are  not 
expected  in  the  SYUs.  Pelleted  urea  dissolves 
slowly  and  is  utilized  by  vegetation  before  it  can  be 
translocated. 

Timber  harvest  affects  stream  temperatures  by 
removing  shading  vegetation  from  streambanks. 
Stream  temperature  increases  of  10    F  or  more 
have  been  recorded  following  removal  of 
streamside  vegetation  by  clearcutting  and  burning 
in  both  the  Oregon  Cascades  and  Coast  Range 
(Brown  and  Krygier  1970;  Levno  and  Rothacher 
1969).  Alternative  8  provides  temperature 
maintenance  for  first  order  and  larger  streams. 
Under  Alternative  1,  removal  of  merchantable 
timber  (see  Table  3-5)  would  reduce  the 
effectiveness  of  buffers  to  provide  adequate  shade, 
resulting  in  increased  temperatures.  Downstream 
shading  does  not  significantly  lower  temperatures 
of  streams  warmed  by  upstream  exposure  (Brown 
etal.  1971). 


65 


Table  3-6  Estimated  Sediment  Yield  From  BLM-Administered  Land, 

First  Decade 

(Tons/Decade) 

From 

From 

Alternative 

Landslides 

Sheet  Erosion 

From  Roads 

Total 

1  (Max.  Tbr.) 

84,100 

303,000 

104,400 

491,500 

2  (Emp.  Tbr.) 

77,300 

176,800 

61,000 

315,100 

3  (Lo  MHS) 

74,500 

153,800 

53,000 

281,300 

4  (OPA) 

72,500 

148,900 

51,400 

272,800 

5  (No  Action) 

55,800 

164,600 

56,800 

277,200 

6(HD) 

53,300 

0 

46,000 

99,300 

7  (No  Herb.) 

49,900 

102,900 

35,500 

188,300 

8  (Full  Eco.) 

25,100 

0 

17,800 

42,900 

9  (NPA) 

72,300 

0 

51,200 

123,500 

Harvest  activities  may  reduce  instream 
concentrations  of  dissolved  oxygen  by  adding 
debris  to  streams.  Fine  organic  debris  (such  as 
small  twigs  and  needles)  uses  dissolved  oxygen 
during  decomposition.  This  depletes  dissolved 
oxygen  concentrations  at  times  of  high  stream 
temperatures,  low  streamflows  and  low  available 
oxygen.  Since  instream  oxygen  concentrations 
quickly  return  to  normal  following  stream  cleanout 
and  fall  rains  (Hall  and  Lantz  1969),  low  instream 
oxygen  concentrations  would  only  be  local  and 
temporary  in  the  SYUs.  However,  oxygen 
concentrations  in  stream  gravel  may  continue  to 
decline  for  several  years  after  logging,  because 
waterflow  through  gravels  is  restricted  by 
sedimentation  (Hall  and  Lantz  1969).  For  this 
reason,  impacts  on  intragravel  oxygen  in  the  SYUs 
would  be  directly  related  to  the  changes  in 
sediment  yield  discussed  above. 

The  effects  of  herbicide  application  on  water 
quality  have  been  described  elsewhere  (USDI, 
BLM  1978).  Design  elements  (see  Chapter  1)  such 
as  buffer  strips  are  expected  to  minimize  herbicide 
drift  or  accidental  direct  spraying  of  water  bodies. 
Amounts  of  herbicide  reaching  streams  beyond 
these  barriers  would  be  insignificant  and  would 
not  adversely  affect  water  quality.  Movement  of 
herbicides  through  the  soil  (leaching)  is  usually 
measured  in  terms  of  inches  or  a  few  feet  (Norris 
1975).  This  is  a  slow  process  that  would  not  lead  to 
stream  contamination,  because  the  herbicide 
would  degrade  before  reaching  free  water  (ibid.). 
For  additional  discussion,  see  Chapter  3,  Impacts 
on  Animals  and  Impacts  on  Human  Health. 

Municipal  Watersheds 

The  cities  of  Riddle,  Canyonville  and  Drain 
have  signed  Memoranda  of  Understanding  (MOU) 
which  outline  practices  to  be  utilized  in  the 
municipal  watersheds.  The  sample  5-year  timber 
sale  plan  water  yield  (see  discussion  of  altered 
water  yields,  this  section)  and  increased 
sedimentation.  Although  an  increase  in  water  yield 


may  be  beneficial,  the  increase  in  suspended 
solids  would  result  in  increased  filtration  costs. 

Conclusions 

Timber  harvest  would  have  very  little  effect 
on  water  yield  in  the  larger  rivers  and  streams. 
Sedimentation  is  expected  to  be  greatest  under 
Alternative  1  and  least  under  Alternative  8. 
Increased  stream  temperatures  can  be  expected  in 
Alternative  1.  There  would  be  469  acres  harvested 
in  municipal  watersheds  in  5  years.  Overall 
impacts  are  greatest  in  Alternative  1  and  least  in 
Alternative  8. 

Impacts  on  Vegetation 

This  section  describes  the  impacts  of 
implementing  a  timber  management  plan  on 
vegetation.  All  impacts  to  wetland  and  aquatic 
vegetation  3-7  shows  the  are  expected  to  be 
insignificant  potential  activity  in  those  watersheds. 


Table  3-7  Proposed  Activities  in 
Municipal  Watersheds  Based  on 
the  Sample  Five-Year  Timber  Sale 
Plan 


Acres  to  be 

Municipal  Watershed 

Sale  Year 

Harvested* 

City  of  Canyonville 

1985 

118 

City  of  Drain 

1985 

160 

City  of  Riddle 

1987 

133 

City  of  Riddle 

1988 

58 

Similar  harvests  have  occurred  in  each  of  these  watersheds  over 
the  past  decade 


66 

The  impacts  of  timber  harvesting  on  municipal 
watersheds  would  be  increased  for  all  alternatives 
except  1.  Under  Alternative  1,  wetlands  would  be 
significantly  impacted  by  harvesting  operations. 
Aquatic  vegetation  would  be  protected  only  to  the 
degree  afforded  streams  under  the  Oregon  Forest 
Practices  Act.  This  would  be  inconsistent  with 
Executive  Orders  11988  and  11990. 

Terrestrial  Vegetation 

Management  treatments  applied  under  each 
alternative  would  impact  the  existing  vegetation  in 
direct  relation  to  the  level  of  treatment  shown  in 
Table  1-2.  Impacts  to  riparian  habitat  are  expected 
to  be  insignificant  under  Alternatives  6,  8  and  9 
(over  18,300  acres  protected).  However,  under 
Alternative  1",  riparian  habitat  would  be  included  in 
adjacent  areas  scheduled  for  final  harvest  and 
subsequent  management  treatments.  Under 
Alternatives  2,  3,  4  and  7,  the  modified  area  control 
concept  would  provide  for  harvest  in  riparian  areas 
(along  third  order  and  larger  streams)  by 
individual  tree  selection,  shelterwood  or  clearcut 
methods.  Alternative  5  would  provide  protection 
for  8,070  acres  along  third  order  and  larger 
streams.  Areas  adjacent  to  first  and  second  order 
streams  would  be  harvested  under  all  alternatives 
except  8  (see  Table  C-4).  The  resulting  impact 
would  be  alteration  of  the  riparian  habitat  in  and 
around  those  areas  where  harvesting  operations 
would  occur.  The  degree  of  impact  would  range 
from  removal  of  the  old  growth  component  where 
individual  trees  are  removed  to  severe  alterations 
where  clearcutting  occurs. 

Timber  harvesting  initiates  plant  succession  by 
creating  openings  in  the  forest  canopy  similar  to 


those  created  by  natural  disturbances.  Different 
cutting  practices  (i.e.,  clearcutting  and  single  tree 
selection  methods)  open  the  canopy  to  varying 
degrees,  thereby  influencing  the  plant  composition 
and  duration  of  the  plant  communities. 

Clearcutting  completely  removes  the  forest 
canopy,  thereby  allowing  the  establishment  of  the 
first  successional  stage  (grass/forb).  Openings  in 
the  canopy  created  by  commercial  thinning,  and  to 
a  lesser  extent  mortality  salvage,  could  result  in 
insignificant  growth  increases  of  understory 
vegetation. 

Vegetation  composition  in  the  SYUs  would  change 
according  to  the  level  of  harvest  proposed  under 
each  alternative.  When  compared  to  the  existing 
forest  profile,  this  change  is  notable  by  a  shift  of 
acreage  from  one  age  class  to  another  (i.e.,  old 
growth  to  non-stocked  or  0-7  year  age  group). 
This  acreage  shift  is  best  shown  by  a  percent 
change  in  individual  age  class  stratification  as 
shown  in  Table  3-8.  Long-term  effects  (first, 
second,  fifth  and  tenth  decades)  were  projected 
and  are  displayed  in  Appendices  E  and  F. 

The  full  scope  of  potential  benefits  that  might 
accrue  from  old  growth  retention  is  yet  unknown. 
Maintaining  a  representative  structural  component 
of  old  growth  Douglas-fir  across  a  range  of 
environmental  variables  until  these  processes  are 
better  understood  may  be  essential  to  maintaining 
the  long-term  productivity  of  timber  stands. 

Yarding  practices  to  be  employed  during  the  10- 
year  period  consist  of  ground  or  partial 
suspension  cable  systems,  cable  with  full 
suspension  and  tractor  systems.  Each  system 


Table  3-8  Approximate  Acres  of  BLM-Administered  Timber  Lands  and  Percent 
of  Change  after  One  Decade 


Habitat  Age 

Current 
Acres 

Alt.  1 
Max.  Tbr. 

Alt.  2 
Emp.  Tbr. 

Alt.  3 
Lo  MHS 

Alt.  4 
OPA 

Alt.  5 

No 
Action 

Alt.  6 
HD 

Alt.  7 
No  Herb. 

Alt.  8 
Full  Eco. 

Alt.  9 
NPA 

Grass/Forb 
Non-stocked  and 
0-7  Years 

34,143 

54,957 
+61% 

50.359 
+47% 

48,293 

+  41% 

46,930 
37% 

29,164 
-15% 

34,066 
<-1% 

32.163 
-6% 

15.212 
-55% 

46.741 

+  37% 

Brush/Seedling 
8-15  Years 

40,853 

42,399 

+  4% 

41,636 
+2% 

41,446 
+  1% 

41,205 
+  1% 

42,621 
+  4% 

39.204 
-4% 

38,773 
-5% 

36,421 
-11% 

41,100 

<  1  % 

Pole  Sapling 
16-45  Years 

56,393 

91.329 
+62% 

91.329 

+62% 

91,329 
+  62% 

91,329 
+62% 

114,097 
-102% 

91,329 

+62% 

91.329 

+62% 

91.329 

+62% 

91.329 
-62% 

Young  2nd  Growth 
46-115  Years 

82,176 

71.010 
-14% 

71,033 
-14% 

71,048 
-14% 

71,054 
-14% 

89,141 
8% 

71,126 
-13% 

71.120 
-13% 

70.538 

-14% 

71,052 
-14% 

Mature 
116-195  Years 

79,807 

74.503 

-7% 

75,736 
-5% 

76.242 

-4% 

76.614 
-4% 

89,885 

- 1 3% 

79.645 

80.418 
1% 

85.171 

-7% 

76.291 

-4% 

Old  Growth 
196+  Years 

1  10,864 

66,527 
-40% 

70,640 
-36% 

72.378 
-35% 

73.604 
-34% 

34.996 

-68% 

85,751 
-23% 

87,623 
-21% 

103,196 

-7% 

74,378 
-33% 

These  columns  may  not  have  the  same  total  acres  due  to  the  differences  in  the  land 
especially  true  for  Alternative  5,  which  also  utilizes  the  1972  land  base  and  inventory 


use  allocations  of  each  alternative.  This  is 


Source:  BLM  allowable  cut  printout  and  district  inventory. 


67 


impacts  ground  vegetation  to  different  degrees 
relative  to  the  soil  disturbance  resulting  from  the 
harvest  system  used. 

Broadcast  burning  is  the  one  method  of  slash 
disposal  proposed  under  each  alternative.  The 
short-  and  long-term  effects  of  burning  are  relative 
to  the  severity  of  the  burn.  According  to  research 
in  the  Coast  Range  of  western  Oregon  (Morris 
1970),  5.8  percent  of  the  total  area  burned  was 
severely  burned.  While  16.6  percent  of  the  area 
remained  unburned,  22.2  percent  and  55.4  percent 
received  moderate  and  light  burns,  respectively. 
The  lighter  burn  provides  a  greater  percent  of 
herbaceous  and  brush  cover  within  the  first  2 
years  after  burning.  Scheduled  replanting  of 
coniferous  seedlings  in  the  area  would  contribute 
to  the  alteration  as  a  fire-induced  plant  community 
became  established.  The  study  also  showed  that 
natural  restocking  of  coniferous  species  was 
approximately  30  percent  greater  on  burned,  as 
compared  to  unburned,  sites  in  the  first  4  years. 

Coniferous  seedlings  raised  in  nurseries  would  be 
planted  (Table  1-2).  Under  the  best  possible  site 
conditions,  rapid  natural  regeneration  could  occur 
every  3  to  7  years,  depending  on  seed  crops. 
Under  artificial  regeneration,  seedlings  are 
generally  planted  the  first  year  following  harvest. 
Because  the  planting  stock  is  already  two  or  more 
years  old,  it  can  have  a  competitive  advantage  on 
good  sites  and  an  even  greater  advantage  on 
poorer  sites.  Therefore,  planting  shortens  the 
amount  of  time  required  for  succession  to 
progress  beyond  the  grass/forb  and 
shrub/seedling  stages.  The  major  long-term 
impact  associated  with  planting  is  that,  by 
increasing  the  competitive  advantage  of  Douglas- 
fir,  early  successional  stages  are  more  quickly 
passed  through,  and  Douglas-fir  attains  site 
dominance  more  rapidly.  This  acceleration  not 
only  reduces  the  residence  time  of  early 
successional  stages  but  also  precludes  the 
development  of  maximum  plant  diversity.  Planting 
an  estimated  15,200  acres  with  genetically 
improved  trees  during  the  10-year  period  would 
not  have  a  significant  effect  on  the  natural  gene 
pool  in  either  the  short  or  long  term.  No  significant 
adverse  long-term  impacts  are  anticipated  with  the 
eventual  planting  of  genetically  improved  trees  on 
90  percent  of  the  intensive  timber  production  base 
for  each  alternative.  Maintaining  a  broad  selection 
of  parent  trees  would  ensure  variability  in  genetic 
base  populations.  The  artificial  regeneration 
program  on  BLM-administered  lands  is  not 
expected  to  significantly  affect  the  stand  or 
species  composition  of  the  entire  Roseburg  Area. 
(BLM  administers  29  percent  of  the  total  forested 
lands.  Compare  Appendices  E  and  F.) 

Herbicides  are  used  to  manipulate  the  species 
composition,  size,  density,  vigor  and  presence  of 
vegetation.  Plant  habitat  altered  by  herbicides 
would  increase  over  that  in  the  past  decade  in  all 


alternatives  except  7  and  8.  Applications  are 
targeted  to  control  grass  and  broadleaf  species  to 
provide  a  competitive  advantage  for  conifers. 
Because  different  herbicides  work  best  for 
selected  target  species,  herbicides  are  often  used 
in  combinations.  In  forestry  applications,  the 
desired  effect  is  acceleration  of  plant  succession 
from  early  successional  stages  to  later  stages 
dominated  by  conifers.  Gratkowski  and 
Lauterback  (1974)  reported  on  the  height  growth 
of  young  Douglas-fir  for  a  5-year  period  after 
release.  Percentage  increase  in  height  growth  over 
non-released  trees  varied  from  130  percent  (for 
trees  one  foot  high  when  spraying  occurred)  to 
149  percent  (for  trees  six  feet  high)  for  basal  spray 
plots  and  from  255  percent  (for  trees  one  foot 
high)  to  171  percent  (for  trees  six  feet  high)  for 
aerial  spray  locations. 

Non-target  vegetation  immediately  adjacent  to 
spray  units  may  be  affected  by  the  movement  of 
herbicides  through  the  air.  Such  impacts  are 
limited,  but  not  eliminated  entirely,  by  buffer  strips 
and  by  application  techniques  (Gratkowski  1974). 
Although  the  direct  vegetational  impacts  of 
herbicide  application  are  short  term,  the  effects  of 
accelerating  the  establishment  of  conifer  stands 
are  long  term.  Once  the  coniferous  stands  become 
dominant  they  remain  until  the  trees  are  harvested 
or  until  natural  disasters  remove  them.  For  greater 
detail  on  herbicides  and  the  provisions  for 
monitoring  of  herbicide  application,  see  the  FEIS 
Vegetation  Management  with  Herbicides:  Western 
Oregon  -  1978  through  1987  (USDI,  BLM  1978). 

Some  timber  stands  would  be  fertilized  under  all 
alternatives  except  5,  7  and  8.  This  practice  would 
result  in  immediate  increases  of  nutrient 
availability  for  all  vegetation  on  the  site.  However, 
resultant  increased  vigor  and  growth  are  directed 
at  commercial  conifer  species.  These  are  short- 
term  impacts  lasting  for  an  average  of  7  years, 
depending  on  site  quality. 

Sensitive,  Threatened  or 
Endangered  Plants 

Unidentified  populations  of  sensitive, 
threatened  or  endangered  plant  species  could  be 
susceptible  to  any  impacts  described  under 
terrestrial  vegetation.  The  direct  effects  of  injury  or 
death  to  the  plants  could  cause  the  immediate 
elimination  of  a  species  in  all  or  a  significant 
portion  of  its  range.  The  more  subtle  effects  of 
vegetative  community  changes  could  cause  the 
eventual  elimination  of  a  species  locally  through 
loss  of  competitive  ability  relative  to  other 
vegetation  on  the  site. 

If  any  species  of  vascular  plant  is  determined  by 
the  U.S.  Fish  and  Wildlife  Service  to  be  threatened 
or  endangered,  any  action  that  contributes  to  its 
extinction  or  to  its  threatened  or  endangered 
status  would  be  in  violation  of  the  Endangered 


68 


Species  Act  of  1973  as  amended.  Therefore, 
environmental  analysis  accomplished  prior  to  any 
site  specific  action  would  include  any  threatened 
or  endangered  plant  species  known  to  be  present 
on  the  site  and  appropriate  measures  to  be  taken. 

Conclusions 

Alterations  to  plant  community  structure  and 
longevity  would  be  the  most  significant  impacts  to 
terrestrial  vegetation  on  those  lands  included  in 
the  timber  production  base.  Continued  timber 
management  would  not  allow  natural  succession 
to  replace  these  communities  because  future 
forests  would  be  harvested  before  they  reached 
the  90-year  age  class. 

Ecosystem  management  assumes  that  every 
component  of  a  naturally  functioning  system 
serves  a  purpose  and  that  each  component 
benefits  the  system.  At  the  present  time,  there  is 
no  definitive  description  of  the  functioning  of  the 
old  growth  system  and  its  importance  to  long- 
range  timber  production. 

The  symbiotic  relationships  between  plants  and 
animals  that  function  in  old  growth  stands  are  not 
fully  understood  and  may  prove  to  be  important  to 
long-term  timber  production.  Until  this  is 
understood,  maintaining  a  representative  range  of 
the  old  growth  forest  and  associated  floral  and 
faunal  genotypes  is  important.  All  alternatives 
would  to  provide  an  adequate  representation  of 
the  original  old  growth  systems  over  the  short 
term. 

The  short-term  use  of  the  commercial  forest  lands 
for  timber  harvest  would  increase  the  long-term 
production  of  wood  fiber  as  old,  slow-growing 
stands  are  replaced  by  young,  fast-growing  stands 
managed  for  optimum  wood  production.  In  the 
long  term,  as  the  area  approaches  a  balance  of  age 
classes,  maximum  growth  of  commercial 
coniferous  species  is  achieved. 

Changes  in  plant  communities  and  habitat  could 
eliminate  some  plant  species  over  the  long  term. 
Intensive  timber  management  practices  such  as 
planting  and  herbicide  application  would  favor 
survival  of  coniferous  trees.  However,  elimination 
of  hardwood  trees,  shrubs  and  herbaceous 
vegetation  would  not  occur. 

An  additional  type  of  impact  involves  the 
management  option  of  using  a  lower  minimum 
harvest  size  (MHS).  A  significant  trade  off  between 
short-term  use  and  long-term  productivity  exists. 
Alternative  3  differs  from  4  in  that  it  utilizes  a  lower 
MHS  (see  Chapter  1).  Over  the  short  term  (the  first 
10  years),  Alternative  3  would  allow  harvest  of  70 
MM  bd.  ft.  (7  MM  bd.  ft./year)  above  that  of 
Alternative  4.  However,  over  the  long  term,  total 
productivity  would  be  less.  Maximum  growth  and 
yield  are  attained  when  a  regulated  forest  is 
achieved,  producing  an  estimated  annual  harvest 


of  303  MM  bd.  ft.  on  the  timber  production  base  of 
Alternative  4.  Alternative  3  would  have  an  annual 
harvest  higher  than  Alternative  4  until 
approximately  the  13th  decade,  when  Alternative  4 
achieves  regulation.  During  this  time,  a  total 
harvest  of  910  MM  bd.  ft.  above  the  Alternative  4 
level  would  be  realized.  Beginning  in  the  13th 
decade,  Alternative  4  would  produce  the  higher 
annual  harvest  (303  MM  bd.  ft.  at  the  regulation 
level)  until  Alternative  3  achieves  regulation  in 
approximately  the  30th  decade.  During  those  17 
decades,  Alternative  4  would  produce  an 
additional  7,990  MM  bd.  ft.  for  harvest.  Therefore, 
over  the  long  term  (at  least  30  decades  into  the 
future),  Alternative  4  would  produce  7,080  MM  bd. 
ft.  more  than  Alternative  3.  A  similar  relationship 
would  exist  for  all  alternatives  which  utilize  a  50 
year  minimum  harvest  age. 

Existing  older  forest  communities  scheduled  for 
final  harvest  would  be  converted  to  early 
successional  stage  communities.  This  impact  is 
unavoidable.  Table  3-9  indicates  the  amount  of  old 
growth  habitat  that  would  be  irretrievably  lost  as 
long  as  those  acres  are  managed  intensively  for 
timber  production  under  all  Alternatives  except  8. 
Permanent  new  road  construction  ranging  from 
1 ,662  acres  in  Alternative  8  to  5,568  acres  under 
Alternative  1  would  result  in  the  unavoidable 
elimination  of  vegetation  on  these  acres. 

Impacts  on  Animals 

Timber  operations  impact  both  animals  and 
their  habitats.  In  most  cases,  the  greatest  and 
longest-term  impacts  occur  on  animal  habitats, 
rather  than  on  individual  animals.  Thomas  (1979), 
Meslow  (1977)  and  Wight  (1974)  have  shown  that 
certain  species  of  vertebrates  are  associated  with 
forests  that  are  of  a  particular  age  class  and 
resulting  structure.  Some  species  habitat 
requirements  are  rigid,  others  are  more  flexible. 
Appendix  D  lists  species  occurring  in  the  SYUs 
and  their  association  with  various  habitats. 

The  predicted  structure  of  habitat  on  BLM- 
administered  forest  lands  (Appendix  E)  was 
calculated  using  the  allowable  cut  runs  and  district 
inventory  data.  In  an  attempt  to  place  BLM  plans  in 
perspective,  the  predicted  structure  of  habitat  in 
the  entire  EIS  area  (as  defined  in  Chapter  2, 
Animals)  was  also  estimated  by  applying 
extremely  rough  projections  of  harvest  levels  (by 
ownership)  on  all  these  lands  over  the  first  10 
decades  (see  Appendix  F). 

Terrestrial  Vertebrates 
Transportation  System 

Road  construction  would  eliminate  vegetation 
from  the  roadbed.  The  acreage  would  vary  (see 
Table  1-2)  depending  on  the  alternative  selected. 
Currently  about  12,000  acres  have  been  cleared  for 
roads.  The  added  impacts  of  habitat  elimination 
would  be  adverse  and  perpetual  since  most  road 


69 


Table  3-9  Acres  of  Old  Growth*  (196+ 

)  and  Percent  Change  from  Existing 

on  BLM-Administered  Lands  Remain 

ing  at  the  End  of  Each  Decade 

(Current:  110,900 

acres) 

Alt.  1 

Alt.  2                                       Alt.  3 

Decade 

Max.  Tbr. 

Emp.  Tbr.                              Lo  MHS 

1 

66,500  (-40%) 

70,600  (-36%)                        72,400  (-35%) 

2 

28,700  (-74%) 

36,300  (-67%)                        40,900  (-43%) 

3 

8,600  (-92%) 

16,600  (-85%)                        28,400  (-74%) 

4 

8,700  (-92%) 

16,400  (-85%)                        27,800  (-75%) 

5 

8,900  (-92%) 

16,600  (-85%)                        27,900  (-75%) 

6 

9,000  (-92%) 

16,100  (-85%)                        26,800  (-76%) 

7 

9,000  (-92%) 

15,700  (-86%)                        25,800  (-77%) 

8 

13,500  (-88%) 

20,500  (-82%)                       31 ,300  (-72%) 

9 

13,600  (-88%) 

21,000  (-81%)                        31,800  (-71%) 

10 

13,700  (-88%) 

21,100  (-81%)                        31,800  (-71%) 

Alt.  4 

Alt.  5                                      Alt.  6 

Decade 

OPA 

No  Action                                  HD 

1 

73,600  (-34%) 

35,000  (-68%)                        85,800  (-23%) 

2 

42,400  (-62%) 

13,000  (-88%)                        66,500  (-40%) 

3 

28,400  (-74%) 

4,800  (-96%)                        59,300  (-47%) 

4 

27,800  (-75%) 

5,000  (-95%)                        57,800  (-48%) 

5 

27,900  (-75%) 

5,400  (-95%)                        58,200  (-48%) 

6 

26,800  (-76%) 

5,500  (-95%)                        55,800  (-50%) 

7 

25,800  (-77%) 

5,600  (-95%)                     .  54,600  (-51%) 

8 

31,300  (-72%) 

6,300  (-94%)                        62,700  (-43%) 

9 

31,800  (-71%) 

6,800  (-94%)                        66,100  (-40%) 

10 

31,800  (-71%) 

7,300  (-93%)                        68,100  (-39%) 

Alt.  7 

Alt.  8                                       Alt.  9 

Decade 

No  Herb. 

Full  Eco.                                   NPA 

1 

87,600  (-21%) 

103,200  (-7%)                        74,400  (-33%) 

2 

71,400  (-36%) 

106,100  (-4%)                        42,800  (-61%) 

3 

53,600  (-52%) 

105,000  (-5%)                        31,000  (-72%) 

4 

53,900  (-51%) 

103,600  (-7%)                        31,000  (-72%) 

5 

56,200  (-49%) 

106,000  (-4%)                        31,800  (-71%) 

6 

55,800  (-50%) 

1 02,400  (-8%)                        31 ,300  (-72%) 

7 

55,400  (-50%) 

101,100  (-9%)                        30,800  (-72%) 

8 

63,700  (-43%) 

1 13,500  (+2%)                        37,000  (-67%) 

9 

67,500  (-39%) 

119,500  (+8%)                        38,200  (-66%) 

10 

70,000  (-37%) 

123,500  (+11%)                     38,900  (-65%) 

*  Rounded  to  nearest  100  acres 

Source:  BLM  allowable  cut  printout  and  district  inventory. 

systems  would  be  maintained  indefinitely. 
Increased  mortality  due  to  collisions  with  vehicles 
is  unpredictable  but  probably  insignificant. 

Harassment  of  wildlife  by  vehicles  undoubtedly 
would  occur  and  during  stress  situations,  such  as 
times  of  temperature  extremes,  would  adversely 
affect  the  animal's  physiological  mechanisms  and 
mortality  could  occur.  Losses  to  this  cause  would 
not  be  expected  to  be  large  or  significant  to  the 
population  as  a  whole.  New  miles  of  roads  mean 
more  access  by  hunters  and  increased  harvest  and 


harassment  is  probable.  Legal  harvest  can  be 
limited  by  regulations  adopted  by  the  Oregon  Fish 
and  Wildlife  Commission  but  an  increase  in 
poaching  is  probable.  This  could  lead  to 
depressed  deer  and  elk  populations  in  local  areas. 

Lyon  (1979)  and  Perry  and  Overly  (1977)  have 
shown  that  elk  use  is  reduced  within  one-half  mile 
of  roads  traversing  elk  habitat.  This  reduced  use 
varies  with  terrain,  cover,  distance  and  other 
factors,  so  an  accurate  quantification  is  possible 
only  on  a  site  specific  basis.  However,  the 


70 


probable  effects  of  a  mile  of  road  through  elk 
habitat  can  be  described  in  general  terms. 
Vehicular  use  of  a  road  will  affect  elk  use  of  the 
adjacent  habitat.  This  influence  on  use  may  extend 
for  at  least  660  feet  on  either  side  of  the  road,  thus 
affecting  an  area  of  160  acres  per  mile  of  road.  It  is 
estimated  that  elk  use  of  this  160  acres  may  be  as 
much  as  75  percent  less  than  that  of  similar  habitat 
not  influenced  by  road  use.  Such  a  reduction  in 
habitat  use  must  be  considered  adverse.  Effects  of 
roads  on  deer  are  "variable  and  relatively 
insignificant"  (Perry  and  Overly  1977,  page  34). 

All  alternatives  contain  provisions  to  close  some 
roads  in  order  to  reduce  harassment  and 
poaching.  Past  experience  has  shown  these 
closures  difficult  to  enforce.  Once  roads  are 
effectively  closed,  elk  use  increases  to  near  normal 
levels.  In  the  Tyee  area  planned  road  closures 
should  improve  elk  use  of  habitat  adjacent  to 
roads. 

Timber  Harvest 

The  greatest  effect  timber  harvest  would 
have  on  terrestrial  vertebrates  during  the  first 
decade  would  be  the  modification  of  habitat  by 
clearcutting.  The  amounts  range  from  66,780  acres 
in  Alternative  1  to  19,915  acres  in  Alternative  8  (see 
Table  1-2).  The  removal  of  mature  and  old  growth 
stands  eliminates  the  habitat  of  those  species  of 
animals  adapted  to  exist  there.  If  similar 
unoccupied  habitat  exists  nearby,  then  those 
displaced  individuals  could  occupy  them.  It  is 
unlikely  that  such  a  situation  exists  as  it  is 
assumed  that  habitats  are  currently  at  carrying 
capacity. 

For  certain  species  (e.g.  elk,  deer,  spotted  owls 
and  other  cavity  dwellers)  which  are  influenced  by 
habitat  availability  and  arrangement,  efforts  will  be 
made  during  the  first  decade  to  schedule  the 
harvest  of  mature  and  old-growth  forest  to  benefit 
these  species  or  to  minimize  adverse  impacts. 

In  the  short  term,  all  alternatives  except  5  would 
have  at  least  65,000  acres  of  old  growth  forest 
remaining.  Although  the  arrangement  of  this 
acreage  may  not  be  optimum  for  all  species,  there 
would  likely  be  sufficient  habitat  after  one  decade 
of  management  to  retain  a  representative 
ecosystem. 

In  Alternatives  3,  4  and  7,  approximately  52,000 
acres  (Table  1-3)  are  proposed  for  modified  area 
control  management,  and  with  the  exception  of 
riparian  zone  habitat  on  third  order  and  larger 
streams,  the  lands  are  confined  to  corridors.  (The 
riparian  zones  are  scattered  across  the  district.) 
Mature  and  old  growth  forests,  a  necessary 
element  of  habitat  diversity,  would  be  located  in 
these  corridors.  These  also  are  the  lands  that 
would  provide  the  major  portion  of  the  snags  for 
cavity  dwellers,  northern  spotted  owl  habitat, 
survival  cover  for  elk  and  ties  to  other  corridors. 


For  Alternatives  2  and  9  the  same  issues  are 
applicable,  but  the  land  area  proposed  for 
management  is  24,800  and  35,900  acres, 
respectively.  In  Alternative  9  no  harvest  is  planned 
from  riparian  zones  on  third  order  and  larger 
streams. 

Currently  there  are  about  110,900  acres  of  old 
growth  (196+  years)  on  BLM-administered  timber 
lands  in  the  SYUs  (Table  3-8).  If  Alternative  8  were 
selected,  old  growth  would  increase  over  time  and 
have  a  beneficial  impact  on  species  using  this 
habitat  (Table  3-8  and  Appendix  E).  However,  if 
any  other  alternative  were  chosen,  old  growth  on 
BLM-administered  land  would  decrease  over  time. 
The  decreases  range  from  37  percent  in 
Alternative  7  to  93  percent  in  Alternative  5  (see 
Table  3-9  and  Appendix  E).  Related  decreases  in 
animals  (see  Appendix  D)  that  find  their  optimum 
habitats  in  these  stages  would  be  probable. 
Examples  are  the  big  brown  bat,  northern  flying 
squirrel  and  pileated  woodpecker.  The  actual 
viable  old  growth  habitat  is  less  than  appears  in 
Appendix  E  because  a  portion  of  the  remaining  old 
growth  would  be  in  riparian  zones  that,  because  of 
their  long,  narrow  configuration,  would  not  have 
true  old  growth  habitat  characteristics.  In  the  long 
term,  enough  mature  and  old  growth  habitat  would 
be  provided  by  Alternatives  6  through  8  to  assure 
maintenance  of  viable  populations  of  animals 
dependent  on  these  habitats.  Alternatives  1 
through  5  and  9  would  not  do  this. 

When  habitat  structure  on  all  lands  in  the  EIS  area 
(see  Chapter  2,  Animals)  is  examined  (Appendix 
F),  old  growth  would  decline  in  all  alternatives.  In 
the  long  term,  all  old  growth  timber  remaining  in 
the  EIS  area  would  be  on  Federal  lands 
administered  by  BLM  and  U.S.  Forest  Service. 
With  this  reduction  of  old  growth  habitat,  a  related 
reduction  of  old  growth  dwelling  populations 
would  be  probable  (see  Appendix  D). 

The  Tyee  area  is  the  most  important  elk  area  in  the 
Roseburg  SYUs.  In  total  it  comprises  about  5 
percent  of  the  State's  Tioga  Wildlife  Management 
Unit,  which  has  historically  produced  the  majority 
of  the  elk  harvested  in  southwest  Oregon. 

Planned  timber  management  activities  in  the  Tyee 
area  would  change  existing  habitat  conditions  and 
influence  elk  populations  as  shown  in  Table  3-10. 
In  the  short  term  elk  populations  would  increase  in 
the  Tyee  area  under  all  alternatives  as  a  result  of 
increased  forage  produced  by  clearcut  harvest, 
provided  that  vehicle  access  does  not  lead  to 
increases  in  harassment  and  poaching.  Planned 
road  closures  should  help  reduce  such  problems. 
For  all  alternatives  the  population  would  peak  in 
the  second  decade,  then  decline  to  a  level  similar 
to  that  which  presently  exists  by  the  end  of  the 
second  decade.  In  the  long  term,  30  to  50  years 
hence,  a  gradual  decline  from  second  decade 
levels  is  expected  for  all  alternatives  except  8.  The 


71 


Table  3-10  Estimated  Elk  Population 
Changes  on  BLM-Administered 
Lands  in  the  Tyee  Area  1 

Alternative 

2nd  Decade 

5th  Decade 

10th  Decade 

1 
2 
3 
4 
5 
6 
7 
8 
9 

No  change 
No  change 
No  change 
No  change 
No  change 
No  change 
No  change 
No  change 
No  change 

-25% 
-25% 
-25% 
-25% 
-10% 
-5% 
-20% 
No  change 
-25% 

-25% 
-20% 
-30% 
-20% 
-20% 
-5% 
-20% 
No  change 
-20% 

1  All  values  ±5  percent 

Source:  BLM  District  and  State  Office  personnel 

estimated  elk  population  50  to  100  years  in  the 
future  is  expected  to  be  20  to  30  percent  less  than 
present  levels  for  Alternatives  1  through  5,  7  and  9. 
Alternative  6  is  expected  to  show  a  5  percent 
decline,  while  Alternative  8  no  change. 

Because  of  its  importance  to  elk,  the  Tyee  area  has 
certain  management  prescription  designs  to 
benefit  elk  in  Alternatives  3,  4,  7  and  9.  They 
include:  30  to  40  percent  of  clearcut  area 
consisting  of  smaller  (15-20  acre)  clearcuts  and  of 
a  shape  which  maximizes  edge  habitat;  a  distance 
to  cover  not  to  exceed  500  feet  within  those 
clearcut  units;  and  a  minimum  cover  width 
adjacent  to  units  of  200  feet.  These  design  features 
along  with  planned  road  closures  would  benefit 
deer  and  elk  and  help  reduce  long-term  adverse 
impacts  in  this  area. 

Decreases  in  mature  habitat  (116-195  years  old) 
would  occur  in  all  alternatives.  The  decreases 
would  have  an  adverse  impact  upon  the  animal 
populations  occurring  there. 

In  Alternatives  1  through  7  and  9,  increases  occur 
in  pole/sapling  and  young  second  growth  and 
associated  animal  populations  would  have 
corresponding  changes  (see  Appendices  E  and  F). 

Early  successional  stages  (1-15  years)  following 
harvest  would  benefit  some  species.  The  savannah 
sparrow,  brush  rabbit,  mountain  beaver,  deer,  elk 
and  mountain  quail  are  examples  of  species  that 
use  early  successional  stages.  There  are  currently 
some  75,000  acres  of  early  serai  stage  (less  than 
15  years  old)  vegetation  on  BLM-administered 
timber  land  and  an  additional  370,000  acres  of  like 
habitat  on  other  ownerships  within  the  SYUs. 
Since  this  stage  presently  comprises  about  30 
percent  of  the  total  land  base  and  will  continue  as 
such  in  the  future,  there  would  be  adequate  levels 
in  both  the  short  and  long  term  to  meet  the  habitat 
needs  of  species  associated  with  these 


successional  stages. 

In  future  decades,  except  for  Alternative  8, 
clearcutting  acreage  would  decrease  while 
commercial  thinning  dramatically  increases. 
Commercial  thinning  would  occur  in  the 
pole/sapling  and  young  second  growth  that 
account  for  the  majority  of  habitat  remaining  at  the 
end  of  10  decades  (see  Table  1-2  for  acreage  to  be 
thinned  during  the  first  decade). 

Commercial  thinning  removes  up  to  40  percent  of 
the  basal  area  of  the  forest  and  has  several  effects 
on  wildlife  habitat.  The  structure  of  the  forest 
becomes  more  simplified  and  animal  species 
diversity  decreases.  The  stand  is  opened  up  and  its 
value  as  thermal  cover  is  reduced  (Edgerton  and 
McConnell  1976).  Hiding  cover  is  also  reduced  and 
forage  may  not  increase,  for  as  Edgerton  (1972) 
pointed  out,  deer  and  elk  use  is  less  in  partial  cut 
areas  (30  percent  basal  area  removed)  than  in 
either  clearcuts  or  unlogged  stands.  These 
alterations  resulting  from  commercial  thinning 
would  result  in  lowered  deer  and  elk  populations 
in  comparison  to  present  day  clearcut 
prescriptions. 

Forest  birds  would  be  affected.  As  Franzreb  and 
Ohmart  (1978)  show,  thinning  decreases  habitat 
value  for  birds  that  forage  by  searching  in  the  tree 
foliage  or  gleaning  in  timber.  Species  such  as  red- 
breasted  nuthatch  and  golden-crowned  kinglets 
would  be  reduced,  while  ground  feeders  such  as 
the  robin  and  house  wren  would  increase. 

Cooper's  and  sharp-shinned  hawks  use  dense 
second-growth  Douglas-fir  as  their  primary 
nesting  habitat  (Reynolds  1971).  The  quality  and 
quantity  of  this  habitat  would  be  reduced  by 
commercial  thinning. 

Commercial  thinning  is  not  expected  to  result  in 
any  significant  adverse  effects  on  wildlife  in  the 
short  term  because  of  the  small  proportion  of  the 
land  base  scheduled  for  treatment. 

The  skidding  of  logs  during  yarding  destroys  low 
vegetation  and  compacts  the  soil.  The  complete 
but  temporary  destruction  of  surface  vegetation 
due  to  yarding  (see  Table  3-2)  would  reduce  the 
amount  of  habitat  for  small  rodents  and 
insectivores.  Ground  disturbances  that  do  not 
remove  excessive  topsoil  may  benefit  local  wildlife 
populations  such  as  elk  and  deer,  seed-eating 
birds  and  certain  rodents  that  depend  on  early 
sucessional  communities.  Swanson  (1970,  cited  in 
Bunnell  and  Eastman  1976)  reported  significantly 
higher  elk  use  on  moderately  or  heavily  disturbed 
sites  than  on  lightly  disturbed  sites. 

Snag-dependent  wildlife  such  as  woodpeckers  and 
other  cavity  dwellers  would  be  adversely  affected 
due  to  snag  removal  during  harvest  operations. 
Based  on  the  work  of  Thomas  (1979),  three  snags 
of  prescribed  sizes  per  acre  would  provide  for 


72 


maximum  populations  of  primary  excavators.  To 
manage  primary  excavators  at  the  60  percent  level 
(considered  a  safe  level)  requires  about  two  snags 
(of  prescribed  sizes)  per  acre.  Most  private  lands 
are  not  routinely  managed  for  cavity  users; 
therefore,  the  habitat  component  maintained  on 
BLM-managed  lands  is  crucial  to  the  survival  of 
snag-dependent  species.  District  surveys  revealed 
that  snags  and/or  wildlife  trees  are  being  provided 
at  the  rate  of  0.1  per  acre  on  recent  harvest  units. 

Using  the  snag  management  components 
displayed  in  Table  C-4,  Table  3-11  was  developed 
to  describe  expected  long-term  snag  densities  on 
the  BLM-administered  land  base. 

As  can  be  seen  from  the  table,  only  Alternative  8 
reaches  the  60  percent  management  level, 
although  Alternatives  6  and  7  are  close.  To  provide 
maximum  wildlife  benefits,  snags  should  approach 
an  even  distribution  throughout  the  land  base. 
Alternative  8  is  the  only  one  that  approaches  even 
distribution. 

During  the  first  decade,  impacts  would  be  minimal 
because  of  the  large  amount  of  unharvested  land 
in  the  SYUs.  However,  for  all  alternatives  except  6, 
7  and  8,  snag  dwelling  species  would  decline  to 
below  BLM  target  levels  in  the  long  term  (see 
Table  3-11).  This  would  be  a  significant  adverse 
impact  as  populations  would  fall  below  self- 
sustaining  levels. 

New  snags  are  created  by  natural  mortality  in  the 
forest.  All  alternatives  except  Alternative  8  would 
employ  some  amount  of  mortality  salvage  during 
the  decade  (see  Table  1-2).  The  number  of  trees 
per  acre,  their  age  and  size  are  variable  and  not 
predictable.  While  in  general  the  impacts  would 


not  be  immediately  significant,  these  trees  are  the 
snags  and  down  forage  logs  of  the  near  future  and 
removing  them  eliminates  potential  and  needed 
habitats. 

Riparian  habitat  is  important  as  88  percent  of  the 
terrestrial  wildlife  species  in  the  area  use  it  to 
some  degree.  The  importance  of  this  habitat  is  the 
result  of  many  factors,  including  cover,  food, 
water,  edge  and  microclimate.  The  maintenance  of 
its  values  depends  on  sustaining  the  structural 
integrity  of  the  vegetation.  Any  alteration  of  its 
structure  decreases  its  value  to  terrestrial  wildlife. 
For  most  riparian  areas,  best  management  for 
wildlife  means  no  entry. 

Table  C-4  shows  how  each  alternative  treats 
riparian  zones.  Alternative  8  is  the  only  alternative 
which  provides  any  protection  to  small  first  and 
second  order  streams  unless  they  occur  in  an  area 
under  other  forms  of  management  in  the 
constrained  timber  base.  Approximately  12,150 
acres  of  this  habitat  (first  and  second  order 
streams)  would  be  modified  and  replaced  by 
younger  vegetation  if  any  alternative  except 
Alternative  8  were  selected.  Riparian  habitat  next 
to  first  and  second  order  streams  is  more  like 
adjacent  upland  habitat  and  its  loss  is  not  as 
important  as  the  loss  of  riparian  habitat  on  higher 
order  streams. 

Riparian  vegetation  on  third  order  and  larger 
streams  would  undergo  some  planned  harvest  in 
all  alternatives  except  Alternatives  6,  8  and  9. 

Alternative  1  would  substantially  alter  riparian 
habitat  and  the  impacts  would  be  significantly 
adverse.  Management  by  modified  area  control  as 
proposed  in  Alternatives  2,  3,  4  and  7  would  also 


Table  3-11  Long-Term  Snag  Density 


Alt. 

Snag/ac 

Percent 

Management 

Level 

1 

0.13 

<10 

2 

0.32 

10 

3 

0.77 

20-30 

4 

0.77 

20-30 

5 

0.21 

<10 

6 

1.43 

40-50 

7 

1.25 

40-50 

8 

2.24 

70-80 

9 

0.77 

20-30 

Snag  Distribution 

Would  not  occur  on  96%  of  land  base; 

adequate  on  4%  of  land  base 
Would  not  occur  on  89%  of  land  base; 

adequate  on  11%  of  land  base 
Inadequate  occurrence  on  82%  of  land  base; 

adequate  on  18%  of  land  base 
Inadequate  occurrence  on  82%  of  land  base; 

adequate  on  18%  of  land  base 
Would  not  occur  on  93%  of  land  base; 

adequate  on  7%  of  land  base 
Would  not  occur  on  47%  of  land  base; 

adequate  on  53%  of  land  base 
Inadequate  occurrence  on  65%  of  land  base; 

adequate  on  35%  of  land  base 
Would  not  occur  on  25%  of  land  base; 

adequate  on  75%  of  land  base 
Inadequate  occurrence  on  82%  of  land  base; 

adequate  on  18%  of  land  base 


73 


alter  riparian  habitats  on  those  acres  entered.  A 
yearly  average  of  12  acres  clearcut  and  96  acres 
partial  cut  of  third  order  and  larger  riparian  zones 
would  be  expected.  The  significance  of  this 
disturbance  is  amplified  as  "Habitat  alteration  [in 
riparian  habitats]  will  affect  wildlife  far  more  than 
indicated  by  the  proportion  of  the  total  area 
disturbed"  (Thomas  1979). 

Food  supplies  for  grazers  and  browsers  are  more 
readily  available  in  the  early  successional  stages 
as  compared  with  other  successional  stages.  Deer 
and  elk  use  would  increase  and  peak  six  to  eight 
years  following  clearcutting  (Harper  1969;  Crouch 
1974).  However,  the  food  supply  may  not  be 
utilized  if  sufficient  hiding  or  escape  cover  is  not 
nearby.  To.assure  sufficient  wildlife  cover, 
clearcuts  should  not  exceed  40  acres.  In  the 
sample  five-year  timber  sale  plan,  59  of  the  953 
sale  units  would  exceed  40  acres  in  size.  The  size 
ranges  from  2  to  51  acres,  but  averages  27  acres. 
Clearcut  size  is  only  part  of  the  mechanism 
necessary  to  provide  cover  near  feeding  areas.  The 
other  is  to  allow  regrowth  to  provide  cover  (about 
10  years)  prior  to  clearcutting  on  adjacent  lands. 
Without  this  timing,  the  forage  created  may  not  be 
utilized  as  no  cover  is  available.  Alternatives  6  and 
8  provide  for  10-  and  15-year  intervals  respectively, 
between  adjacent  clearcut  units,  and  all  other 
alternatives  provide  for  at  least  3-  to  5-year 
intervals.  As  part  of  harvest  scheduling  design 
features,  a  10-year  interval  would  be  applied  to  all 
lands  under  Alternative  9,  where  possible  during 
the  first  decade,  so  long  as  it  did  not  limit  the 
ability  to  meet  the  prescribed  allowable  cut. 
Should  conflicts  arise  between  the  10-year  spacing 
standard  and  meeting  the  allowable  cut  level,  the 
interval  would  be  lowered.  Such  design  features 
serve  to  distribute  harvest  units,  mitigating  adverse 
impacts  to  species  which  utilize  mature  and  old- 
growth  forest  habitat. 

Other  Timber  Management 
Treatments 

Other  treatments  (Table  1-2)  alter  animal 
habitat  through  vegetative  manipulation. 

Slash  burning  would  eliminate  most  live  vegetation 
from  the  site  and  80  to  90  percent  of  the 
combustible  material  less  than  three  inches  in 
diameter  would  be  consumed.  Larger  material  is 
generally  charred  in  place.  Table  1-2  lists  acres  to 
be  burned  for  all  alternatives.  These  effects  vary 
with  the  intensity  of  the  burn,  but  immediate 
impacts  would  be  removal  of  vegetation  and  on 
site  reduction  of  associated  animal  populations. 
This  would  last  less  than  one  growing  season, 
after  which  a  vigorous  growth  of  grasses  and  forbs 
would  appear  and  animal  populations  adapted  to 
early  successional  stage  vegetation  would 
increase. 


The  removal  of  woody  material  reduces 
obstructions  to  deer  (Crouch  1974).  Other  species 
such  as  juncos  and  wrens  use  logging  slash  as 
activity  centers.  Juncos  declined  when  slash  was 
burned  (Franzeb  and  Omart  1978).  Charring  of  the 
larger  material  removes  bark  and  eliminates  micro- 
habitats  for  invertebrates  that  are  an  important 
item  in  the  food  chain.  In  addition,  the  resulting 
habitats  lack  structure  that  slash  provided  and  are 
more  simplified. 

Harper  (1969)  reported  higher  Roosevelt  elk  use 
on  logging  sites  that  had  been  burned  than  on 
those  that  had  not  been  burned,  and  explains  that 
on  burned  sites  grasses  were  more  than  three 
times  as  abundant.  Grasses  are  a  preferred  food 
item  of  elk.  He  warned,  however,  that  slash 
burning  would  not  necessarily  increase  forage  and 
subsequent  elk  use  on  all  sites  as  physical 
characteristics  make  each  site  different  in  its 
response  to  burning.  Also,  Crouch  (1974) 
indicated  that  slash  burning  increased  the  food 
supply  for  black-tailed  deer.  In  the  Roseburg  SYUs 
grasses  are  commonly  found  in  the  early  serai 
stage  plant  communities.  Some  clearcut  units 
throughout  the  district  are  dominated  by  grasses. 
This  includes  clearcuts  in  the  Tyee  area,  the 
primary  elk  use  area. 

Mechanical  piling  of  slash  would  cause  soil 
disturbance  and  have  impacts  similar  to  those 
caused  by  yarding.  Piling  removes  downed  slash 
that  may  cause  barriers  to  large  ungulates. 
Subsequent  burning  removes  these  barriers  and 
enough  debris  may  be  left  to  provide  habitat  for 
some  birds  and  small  mammals. 

All  alternatives  except  Alternative  7  call  for 
herbicide  use  in  site  preparation  and  conifer 
release  during  the  decade.  The  impacts  from  all 
alternatives  except  Alternative  7  are  the  same,  only 
the  magnitude  changes.  (See  Table  1-2  for  acres 
treated.) 

There  are  four  major  types  of  impacts  to  animals 
that  could  be  associated  with  silvicultural 
herbicide  application:  exposure  to  acute  toxic 
levels,  exposure  to  chronic  toxic  levels,  habitat 
modification  and  carrier  impacts.  The  following  is 
a  brief  discussion  of  these  four  impacts.  Additional 
information  may  be  obtained  from  the  final  EIS  on 
herbicides  (USDI,  BLM  1978). 

Newton  and  Norris  (1968)  sampled  blacktail  deer 
taken  from  treated  sites  (2,4,5-T  &  Atrazine),  and 
were  unable  to  detect  residues  in  most  tissues. 
One  animal  was  found  to  have  a  trace  in  the  liver. 
In  a  study  by  the  manufacturer,  goats  given  0.2  mg 
triclopyr/kg  daily  for  10  days  were  found  to  have 
tissue  residues  above  the  detection  limit  of  0.003 
ppm  in  only  the  liver  (0.004  ppm)  and  kidney 
(0.013  ppm). 


74 


According  to  Dost  (1983),  if  an  assumption  of  feed 
intake  by  deer  at  3  percent  of  body  weight  per  day 
is  taken,  at  the  hypothetical  maximum  of  400  ppm 
of  herbicide  in  browse,  intake  will  be  30  grams 
feed/kg  or  12  mg  herbicide/kg.  In  the  goat  study 
the  maximum  concentration  in  muscle  was 
between  zero  and  0.003  ppm,  and  will  be  taken  as 
0.003  ppm.  Studies  in  other  species  show  that 
tissue  concentration  is  proportional  to  dose  rate. 
The  proportional  concentration  in  the  animal's 
muscle  would  be  0.18  ppm  (0.18  mg/kg)  and/0.24 
ppm  (0.24  mg/kg)  and  0.78  ppm  (0.78  mg/kg)  in 
the  liver  and  kidney  respectively.  To  acquire  these 
dosage  levels,  an  animal  would  have  to  forage  in 
freshly  treated  areas  for  10  consecutive  days 
providing  there  would  be  no  chemical  breakdown 
or  deterioration.  Therefore,  the  potential  for 
wildlife  to  suffer  acute  or  chronic  toxic  effects  is 
unlikely  at  proposed  herbicide  use  rates  (see 
Tables  1-4  and  3-17). 

Herbicides  have  pronounced  impacts  on  wildlife 
habitat.  These  impacts  are  brought  about  by 
losses  of  habitat  diversity  and  stratification 
resulting  from  the  temporary  setback  of  certain 
plants  that  are  in  competition  with  the  desired 
coniferous  species.  This  would  adversely  impact 
those  animals  that  utilize  the  grass/forb  and 
shrub/seedling  successional  stages. 

Diesel  oil  is  sometimes  used  as  a  carrier  for  forest 
herbicides.  Data  on  the  toxicity  of  diesel  oil  on 
wildlife  are  limited;  however,  some  work  has  been 
done  on  the  adverse  effects  on  adult  ducks 
(Tucker  and  Crabtree  1970;  Hartung  1966;  Hartung 
1965).  It  is  unlikely  that  wild  animals  would 
consume  lethal  amounts  of  the  carrier  because  of 
the  dilution  factors  involved.  It  may,  however, 
adversely  affect  the  palatability  of  the  forage. 
Other  potential  impacts  include  the  coating  of 
eggs,  thereby  affecting  their  hatchability,  and  the 
wetting  of  individuals,  making  them  more 
susceptible  to  other  environmental  stresses. 
However,  data  are  insufficient  to  predict  the 
impacts  of  diesel  oil  carrier  on  animals  in  the  EIS 
area. 

Precommercial  thinning,  although  it  may  open  a 
young  forest  canopy,  generally  does  not  benefit 
deer  and  elk  because  the  unremoved  slash 
impedes  movements.  The  obstacle  presented  by 
slash  accumulations  restricts  deer  and  elk  from 
utilizing  any  forage  increases  which  result  from 
the  thinnings.  Cover  use  is  also  restricted  by  slash 
accumulations.  Therefore,  reduced  deer  and  elk 
use  would  occur  on  those  acres  precommercially 
thinned  (see  Table  1-2).  This  condition  could  last 
as  long  as  two  decades  before  decomposition 
removed  the  obstacles. 

Conversely,  birds  and  small  mammals  may 
increase  their  use  of  an  area  following 
precommercial  thinning.  Slash  accumulations 
provide  cover  for  them  and  any  increases  in  forage 
production  can  be  utilized. 


Fertilization  increases  the  growth  and  palatability 
of  many  plant  species.  These  increases  may  be 
utilized  by  wildlife  which  would  be  a  short-term 
positive  impact. 

Fish 

Impacts  of  timber  management  on  fish  and 
aquatic  habitat  fall  into  the  broad  categories  of 
increased  accumulation  of  bottom  sediments, 
increased  amounts  of  suspended  sediments, 
altered  amounts  of  stream  flow,  introduction  of 
logging  debris,  change  of  water  temperature, 
destabilization  of  banks  and  channels  and 
reduction  of  instream  structure. 

The  impacts  from  the  nine  alternatives  differ 
primarily  in  magnitude.  These  differences  reflect 
the  acres  of  land  treated  and  miles  of  road  built. 
For  instance,  Alternative  8  has  the  fewest  miles 
constructed,  while  Alternative  1  has  the  most  miles 
of  road  constructed.  (See  Table  1-2  for  all 
treatments.) 

On  lands  administered  by  BLM  in  the  SYUs,  there 
are  approximately  270  miles  of  streams  that 
support  cold  water  fish  (see  Table  2-11).  Analysis 
of  the  sample  5-year  timber  sale  plan  shows  that 
approximately  17  miles  of  stream  that  support  cold 
water  fish  pass  through  or  are  adjacent  to  77 
harvest  units. 

Aquatic  invertebrates,  which  are  important  both  as 
food  for  fish  and  as  indicators  of  stream  quality, 
can  also  be  modified  or  destroyed  by  the  same 
factors  that  affect  fish  habitat.  It  is  assumed  that 
impacts  to  most  invertebrates  would  be  similar  to 
those  experienced  by  fish  in  localized  areas. 
Research  by  Erman  et  al.  (1977)  revealed  that 
when  buffer  strips  of  at  least  30  meters  (about  98 
feet)  width  on  each  side  were  maintained,  the 
macro-invertebrate  populations  were 
indistinguishable  from  those  of  unlogged  stream. 

Maintenance  of  buffers  helps  minimize  stream 
degradation.  Since  Alternative  1  has  no  provisions 
for  buffer  strips  except  as  provided  by  the  Oregon 
Forest  Practices  Act,  stream  productivity  might  be 
adversely  affected. 

Chapter  3,  Impacts  on  Water  Resources,  provides 
data  on  expected  amounts  of  sediments  and  water 
that  would  reach  the  streams  of  the  SYUs  and 
compares  them  to  existing  amounts.  Many  of  the 
analyses  and  conclusions  appearing  in  this  section 
are  based  on  those  data. 

Transportation  System 

The  construction  of  roads  can  add  greatly  to 
the  sediment  load  of  a  river.  In  Alternatives  1,  2,  3, 
4  and  9,  road  building  during  the  decade  would  be 
more  than  in  the  past  decade;  however, 
sedimentation  from  road  building  would  be 
increased  only  in  Alternatives  1  and  2  (see  Table  3- 
6).  Analysis  of  the  sample  five-year  timber  sale 


75 


plan  shows  about  three  miles  of  road  would  be 
built  on  fragile  or  unstable  soils  that  are  adjacent 
to  streams  with  fishery  values.  If  sedimentation 
increased,  the  impacts  would  be  adversely 
significant  to  localized  areas.  Downstream 
sedimentation  could  occur  and  could  have 
significant  effects. 

In  discussing  impacts  to  the  aquatic  invertebrates, 
Erman  et  al.  (1977)  suggest  that  repeated  failure  of 
road  crossings  was  the  cause  of  disruption  of  the 
stream  biota,  not  the  construction  of  road 
crossings.  Investigations  in  the  vicinity  of  newly 
installed  culverts  showed  only  a  slight  impact. 

Three  new  roads  identified  in  the  sample  five-year 
timber  sale  plan  would  cross  streams  with  fishery 
values.  All  are  on  stable  soils  so  only  short-term 
localized  impacts  are  expected. 

Timber  Harvest 

Timber  harvest  can  have  an  adverse  impact  on 
fish  habitat  by  removing  the  riparian  zone, 
changing  water  yield  and  increasing 
sedimentation. 

Removing  the  riparian  zone,  including  old  growth 
conifers,  would  increase  the  amount  of  fine 
organic  material,  reduce  the  number  and  quality  of 
pools,  reduce  useable  spawning  gravels,  reduce 
macro-invertebrate  production  areas,  destabilize 
banks  and  channels,  and  increase  water  velocities. 
Logging  riparian  zones  would  also  increase 
sedimentation  of  stream  bottoms  and  change 
temperature  regimes  by  decreasing  shade. 
However,  where  some  streamside  vegetation  is 
retained,  no  change  in  temperature  was  observed 
(Brown  and  Krygier  1970).  Water  temperatures 
would  not  increase  if  Alternatives  2  through  9  were 
selected.  Alternative  1  makes  no  provision  for 
riparian  buffers  and  water  temperatures  would  be 
expected  to  increase.  These  increases  are  not 
quantifiable  but  impacts  are  expected  to  be 
adverse. 

Clearcutting  increases  water  yield  (see  Impacts  on 
Water  Resources),  which  could  have  a  scouring 
effect  on  stream  bottoms,  thereby  removing  gravel 
and  aquatic  vegetation.  Based  on  the  analysis 
described  in  Chapter  3,  it  is  estimated  that  water 
yield  changes  would  have  a  negligible  impact  to 
the  SYUs  as  a  whole. 

Harvest  and  yarding  could  contribute  considerable 
sediment  to  local  streams.  Increases  in  bottom 
sediments,  according  to  Gibbons  and  Salo  (1973), 
cause  the  most  damage  of  all  factors  affecting 
aquatic  life.  The  amount  of  sedimentation  would 
depend  on  the  alternative  selected.  Alternatives  4, 
6,  7,  8  and  9  would  reduce  sedimentation 
compared  to  past  activities,  while  Alternatives  1,  2 
and  3  would  result  in  an  increase  (see  Table  3-6). 

While  changes  in  fish  production  cannot  be 
quantified,  any  increase  in  sediment  would  have 


an  adverse  impact  while  decreases  would  be 
beneficial. 

Other  Timber  Management 
Treatments 

Burning,  animal  damage  control,  precommercial 
thinning  and  fertilization  are  not  expected  to  have 
a  significant  impact  on  fish. 

The  chemicals  proposed  for  use  for  vegetation 
control  and  the  levels  of  their  application  are  not 
expected  to  measurably  affect  aquatic  vegetation. 
Streamside  vegetation  that  provides  shade  could 
be  altered  in  a  worst  case  circumstance.  Buffer 
strips  along  streams  should  prevent  this  from 
occurring.  However,  due  to  pilot  error,  some  parts 
of  these  buffer  strips  could  receive  applications, 
and  some  detectable  amounts  could  reach  the 
stream. 

Toxic  effects  of  herbicides  on  fish  have  been 
documented  in  the  laboratory  (U.S.  EPA  1977). 
However,  proposed  field  application  rates  would 
be  considerably  less  than  the  minimum  lethal  dose 
for  those  species  tested  and  toxic  effects  are  not 
expected.  (See  BLM's  FEIS  Vegetation 
Management  with  Herbicides,  Western  Oregon 
1978  through  1987,  for  more  detailed  information.) 
It  should  be  noted  that  long-term  effects, 
particularly  under  field  conditions,  are  more 
difficult  to  determine  than  are  effects  in  short-term 
laboratory  tests.  Also,  Cameron  and  Anderson 
(1977)  felt  that  more  study  use  was  needed  in 
order  to  evaluate  the  impacts  to  aquatic  plants  and 
animals  under  field  conditions.  However,  Cameron 
and  Anderson's  monitoring  program  in  1977  and 
Anderson's  monitoring  in  1979  showed  that 
amounts  of  herbicides  in  streams  did  not  exceed 
EPA's  "safe"  level  standards. 

Threatened  and  Endangered 
Animals 

Threatened  and  endangered  species  receive 
special  attention  under  the  terms  of  the 
Endangered  Species  Act  of  1973,  as  amended,  and 
BLM  policies  and  guidelines.  Known  locations  of 
these  species  are  managed  and  special 
precautions  taken  to  ensure  their  well-being.  (See 
Chapter  1,  Forest  Management  Treatments  and 
Design  Elements.)  Because  of  their  habitat 
requirements  and  locations,  no  impacts  are 
expected  to  occur  to  the  Columbian  white-tailed 
deer  and  the  bald  eagle. 

Transportation  System 

Threatened  or  endangered  species  would 
probably  be  affected  only  to  the  extent  that  road 
construction  could  open  previously  inaccessible 
areas.  This  impact  cannot  be  quantified  or 
qualified.  Where  road  construction  may  affect  a 
given  species,  special  measures  are  taken  to 
prevent  significant  adverse  impacts. 


76 


Timber  Harvest 

Habitat  modifications  caused  by  clearcutting 
would  have  long-term  adverse  impacts  on  old 
growth-dwelling  species.  The  northern  spotted 
owl,  a  State-listed  species,  is  dependent  on  old 
growth  closed-canopy  forests  and  would  be 
greatly  affected. 

The  original  Oregon  Endangered  Species  Task 
Force  management  recommendations  for  each 
pair  of  owls  (in  effect  during  the  preparation  of  the 
proposed  MFP)  called  for  total  protection  of  a  300- 
acre  old  growth  core  area  (if  available)  and  an 
additional  900  acres  to  be  managed  such  that  at 
least  50  percent  of  this  acreage  would  occur  as 
stands  of  30+  year-old  forests.  Based  on  these 
recommendations,  Alternatives  3,  4  and  7  would 
protect  habitat  for  18  pairs  in  the  long  term. 
Alternative  9  would  provide  habitat  for  18  pairs 
under  the  recommendations,  plus  an  additional 
pair  by  other  allocation  for  a  total  of  19  pairs  in  the 
long  term.  It  is  highly  probable  that  at  least  25 
viable  pairs  would  remain  at  the  end  of  the  first 
decade  as  a  result  of  land  use  allocations  and 
harvest  scheduling.  Alternative  6  would  protect 
habitat  for  25  pairs,  and  Alternative  8,  habitat  for 
55  pairs  in  the  long  term.  Alternatives  1,  2  and  5 
have  no  provisions  to  protect  owls  in  either  the 
short  or  long  term. 

Examination  of  the  sample  five-year  sale  plan 
reveals  planned  harvest  units  would  involve  the 
habitat  of  23  of  the  55  known  pairs.  Consideration 
will  be  given  to  scheduling  harvest  units  to 
eliminate  or  reduce  adverse  impacts. 

A  revision  of  Task  Force  recommendations  has 
resulted  from  recent  data.  The  revision 
recommends  that  forests  be  managed  to  provide 
1,000  acres  of  old  growth  per  pair  of  owls  within  a 
1.5  mile  radius  of  nest  sites.  Currently,  42  pairs 
occupy  habitat  that  meets  this  criterion.  The 
following  analysis  of  the  relationship  of  the 
alternatives  to  spotted  owl  habitat  is  based  on  the 
assumption  that  the  revised  recommendations 
identify  minimum  essential  habitat.  Land  use 
allocations  in  Alternatives  6  and  8  would  provide 
enough  habitat  for  24  and  42  pairs  respectively  in 
both  the  short  and  long  term.  None  of  the  other 
alternatives  would  provide  habitat  for  any  owls  in 
the  long  term.  Because  timber  sale  locations 
beyond  the  five-year  plan  are  not  known,  it  is  not 
possible  to  predict  when  various  pairs  would  have 
their  habitat  removed. 

Conclusions 

With  the  exception  of  Alternative  8,  both 
short-  and  long-term  reductions  of  old  growth 
would  have  an  adverse  impact  on  old  growth 
species.  In  the  short  term  adequate  habitat  would 
exist  for  viable  population  levels  of  old-growth 
related  species  in  all  alternatives  except  5.  Short- 
term  habitat  diversity  will  improve  under  all 


alternatives  as  the  serai  stage  mix  is  enhanced  by 
harvest  and  succession.  Alternatives  1,  2  and  5 
significantly  reduce  mature  and  old  growth  habitat 
in  the  long  term,  and  selection  of  one  of  these 
alternatives  would  have  significant  adverse 
impacts  on  old  growth  species  and  habitat 
diversity.  In  the  long  term,  intensive  forest 
practices  in  Alternatives  1,  2,  3,  4,  5  and  9  would 
lead  to  even-aged  stands  that  would  significantly 
reduce  habitat  diversity  and  adversely  impact 
wildlife. 

Simplification  of  forest  habitats  would  also  have  a 
significant  effect  on  wildlife.  Pole,  sapling  and 
young  second  growth  (which  would  account  for 
most  of  the  forests,  except  in  Alternative  8)  have 
low  environmental  variables  (simple  structure) 
even  under  natural  conditions.  Further  loss  of 
structure  from  thinning  would  make  these  age 
classes  of  very  low  value  for  most  wildlife.  Further 
simplification  resulting  from  broadcast  burning 
and  herbicides  would  add  to  the  loss  of  diversity. 
This  long-term  simplification  and  loss  of  diversity 
would  be  significant  and  adverse. 

During  the  short  term,  snag-dependent  wildlife 
would  decline  but  remain  at  viable  levels. 
Continued  decline  in  the  long  term  would  reduce 
populations  below  viable  levels  in  Alternatives  1 
through  5  and  9.  This  is  a  significant  adverse 
impact.  Alternatives  6  and  7  would  support 
marginal  populations  while  Alternative  8  would 
provide  for  adequate  numbers. 

Riparian  habitat  occupies  about  3  percent  of  the 
forest  land  base  and  is  used  by  88  percent  of  the 
terrestrial  wildlife  species.  This  crucial  habitat 
would  be  adequately  protected  through  the 
selection  of  Alternatives  6,  8  or  9.  Selection  of  any 
other  alternative  would  result  in  varying  degrees  of 
adverse  impact  to  riparian  habitat.  Alternatives  1 
and  5  would  result  in  significant  adverse  impacts 
to  this  habitat. 

Habitat  removed  by  road  construction  is  assumed 
to  be  permanently  and  irretrievably  lost  on  those 
roads  proposed  as  part  of  the  permanent  road 
system.  The  construction  of  new  roads  would  lead 
to  harassment  of  wildlife  and  reduce  useable  elk 
and  large  carnivore  habitat  within  one-quarter  mile 
of  these  roads.  Planned  road  closures,  if  effective, 
would  reduce  this  impact. 

Deer  numbers  are  not  expected  to  be  greatly 
modified  by  any  of  the  alternatives  in  the  short 
term,  but  once  commercial  thinning  dominates  the 
harvest,  beginning  in  the  sixth  decade,  populations 
may  be  reduced.  Because  of  different 
requirements,  elk  numbers  would  be  influenced  by 
many  of  the  alternatives.  The  changes  would  be 
due  to  changing  habitat  conditions,  new  road 
construction,  thinning  and  other  habitat  modifiers. 

No  adverse  impacts  to  elk  are  expected  in  the 
short  term.  Elk  populations  would  in  fact  increase, 


77 


peaking  in  the  second  decade.  In  the  long  term,  30 
to  50  years  hence,  a  gradual  decline  from  second 
decade  levels  is  expected  for  all  alternatives 
except  8.  The  estimated  population  in  50  to  100 
years  is  expected  to  be  20  to  30  percent  less  than 
present  levels  for  Alternatives  1  through  5,  7  and  9. 
Alternative  6  is  expected  to  show  a  5  percent 
decline,  while  Alternative  8  would  result  in  no 
change.  In  the  long  term  projected  declines  in  elk 
production  on  Roseburg  District  lands  may  place 
additional  demands  for  elk  production  on  other 
federal  lands  including  the  Umpqua  National 
Forest,  which  adjoins  the  east  boundary  of  the 
Roseburg  District. 

If  it  is  assumed  current  fish  populations  reflect 
conditions  and  harvest  regulations  over  the  past 
decade,  then  itcan  be  assumed  that  fish 
populations  would  decline  under  Alternatives  1 
through  3  due  to  increased  sedimentation.  Fish 
would  increase  in  Alternatives  4,  6,  7,  8  and  9  and 
remain  the  same  under  Alternative  5.  The 
population  changes  cannot  be  quantified. 

The  northern  spotted  owl  is  the  only  species  listed 
by  the  State  of  Oregon  as  threatened  that  would 
be  adversely  impacted.  The  original 
recommendations  of  the  Oregon  Endangered 
Species  Task  Force  influenced  the  proposed 
alternatives  for  the  EIS  area.  Assuming  that  these 
recommendations  identify  minimum  essential 
habitat,  18  of  the  55  known  owl  pairs  in  the  SYUs 
would  be  fully  protected  in  the  long  term  by 
Alternatives  3,  4  and  7,  19  pairs  by  Alternative  9,  25 
pairs  by  Alternative  6,  and  55  pairs  by  Alternative 
8.  A  recent  revision  of  the  Task  Force 
recommendations  indicates  that  minimum  habitat 
requirements  may  be  greater.  If  so,  Alternatives  6 
and  8  would  provide  habitat  for  24  and  42  pairs 
respectively.  No  other  alternative  would  support 
any  owls  in  the  long  term. 

In  all  of  western  Oregon  the  combined  BLM  timber 
management  decision  for  Medford  and  Coos  Bay 
districts  and  the  new  preferred  alternatives  for  the 
Eugene,  Roseburg  and  Salem  districts  would  come 
close  to  meeting  the  original  Oregon  Endangered 
Species  Task  Force  recommendation  for 
protection  of  the  northern  spotted  owl.  At  the  end 
of  the  first  decade  it  is  expected  that  all  western 
Oregon  BLM  districts  combined  would  maintain  at 
least  90  pairs  of  owls,  resulting  from  allocations 
made  in  land  use  plans  and  harvest  scheduling. 

Cumulative  adverse  impacts  are  expected  to  be 
minimal  in  the  short  term.  Habitat  for  an  estimated 
78  of  the  recommended  90  pairs  would  be 
provided  long-term  protection  through  the  land 
use  planning  process.  In  the  long  term  a  BLM 
shortfall  in  providing  the  recommended  portion  of 
owl  pairs  may  result  in  a  significant  adverse  impact 
to  the  species  unless  the  unmet  needs  were 
reapportioned  by  the  Oregon  Endangered  Species 
Task  Force. 


Impacts  on  Recreation 

The  impacts  of  timber  management  on 
recreation  are  related  to  changes  in  the  physical 
setting.  From  the  setting,  recreationists  derive 
different  satisfactions,  experiences  and  benefits. 
As  changes  in  the  setting  affect  experiences,  levels 
and  patterns  of  visitor  use  change.  For  example,  in 
one  area  recreation  use  might  be  facilitated  by 
road  construction.  In  another  area,  visitation  may 
show  a  long-term  decline  if  the  area's  setting  or 
resource  availability  is  significantly  altered.  Some 
visitors  may  relocate  to  other  areas  where 
opportunities  for  desired  experiences  exist. 

Each  alternative  varies  in  approach  and  emphasis 
on  meeting  recreational  needs.  Some  localized 
recreational  demand  would  not  be  met  if  areas  and 
facilities  are  not  provided.  The  provision  of  areas 
and  facilities  for  recreational  pursuits  would  be 
beneficial  since  opportunities  would  be  available 
to  meet  increasing  demand  (Chapter  2,  Table 
2-13). 

As  natural  or  natural-appearing  environments  are 
altered  due  to  timber  harvest,  opportunities  related 
to  appreciation  of  the  natural  environment  are 
reduced.  Opportunities  for  such  activities  as 
camping,  hiking,  fishing,  hunting,  nature  study  and 
sightseeing  would  be  degraded  in  some  areas.  The 
degree  and  magnitude  of  impact  would  be 
dependent  upon  the  level  of  intensive  timber 
management  under  each  alternative. 

The  alternatives  provide  for  varying  degrees  of 
protection,  use  and  maintenance  of  existing 
recreation  sites.  Generally,  Alternatives  1  and  5 
have  minimal  or  no  provisions  to  preserve 
opportunities  for  additional  recreation  site 
development.  Alternatives  2,  3,  4,  6,  7,  8  and  9 
allow  for  the  protection  of  recreation  development 
opportunities.  Assuming  these  developments  are 
realized,  these  alternatives  would  adequately  meet 
increasing  demand  on  public  lands  related  to  such 
activities  as  camping,  picnicking,  hiking, 
horseback  riding,  swimming  and  water-oriented 
use  (see  Appendix  C,  Table  C-4). 

Clearcutting  can  enhance  certain  recreational 
activities  such  as  hunting,  collecting,  berry 
picking,  general  sightseeing,  picnicking  and  using 
ORVs  by  creating  areas,  improving  access  or 
providing  openings  for  scenic  views.  The  impacts 
of  clearcutting  would  be  most  significant  under 
Alternative  1  and  moderately  significant  under 
Alternatives  2,  3,  4,  7  and  9.  Alternatives  5  and  6 
call  for  levels  of  clearcutting  similar  to  that  under 
the  existing  situation.  Under  Alternative  8, 
clearcutting  would  be  significantly  less  than  under 
the  existing  situation. 

Many  timber  management  activities  create  noise, 
odors,  dust,  fumes  and  additional  traffic.  Some 
recreational  opportunities  would  be  degraded  by 


78 

these  factors.  However,  many  road-oriented 
dispersed  recreationists  indicate  that  impacts  of 
timber  management  do  not  detract  from  their 
enjoyment  (Downing  and  Clark  1979). 

Area-wide  impacts  to  fishing  and  hunting  success 
are  dependent  upon  impacts  to  the  species  (see 
Impacts  on  Animals).  In  the  short  term,  demand 
for  hunting  (see  Table  2-13)  would  be  met  under 
all  alternatives.  In  the  long  term,  elk  population 
decreases  under  all  alternatives  except  6  and  8 
(see  Table  3-11)  are  expected  to  lead  to  decreased 
elk  hunting  opportunities  and  a  corresponding 
reduction  in  hunter  use.  Declining  fish  populations 
under  Alternatives  1,  2,  3  and  5  are  expected  to 
result  in  a  similar  reduction  in  fishing 
opportunities  and  related  angler  use  (see  Impacts 
to  Animals,  Conclusion).  Decreased  hunting  and 
fishing  opportunities  could  result  in  a  relocation  of 
these  recreationists  to  other  areas. 

Vehicular  access  would  be  improved  as  a  result  of 
new  road  construction.  The  beneficial  and  adverse 
impacts  on  recreation  would  be  most  apparent 
under  Alternative  1  and  least  apparent  under 
Alternative  8. 

Analysis  of  the  sample  5-year  timber  sale  plan 
indicates  that  slight  reductions  or  increases  in 
visitor  use  could  occur  at  specific  sites.  Clearcut 
units  near  Severt  Iverson  County  Park,  Berry 
Creek  Reservoir  and  Cavitt  Creek  County  Park 
may  create  slightly  adverse  visual  and  auditory 
impacts  which  would  degrade  the  recreation 
experience  for  some  facility  users.  Harvest  units  in 
areas  offering  off-road  vehicle  opportunities 
(Yellow  Creek  Mountain,  Hubbard  Creek, 
Deadman  Mountain)  would  not  create  significant 
adverse  impacts  but  could  result  in  slight 
increases  in  visitor  use  at  these  areas. 

Timber  harvest  in  the  vicinity  of  potential  hiking 
and  equestrian  trails  could  degrade  the  recreation 
experience  for  most  future  trail  users  but  could 
also  provide  clearings  with  scenic  viewing 
opportunities.  Such  impacts  could  occur  along 
potential  trails  in  the  following  areas:  Berry  Creek, 
Tyee,  North  Umpqua-south  side,  Old  Fairview, 
Silver  Butte  and  White  Rock. 

Environmental  assessments  which  precede  each 
timber  sale  will  provide  a  site  specific  analysis  of 
these  potential  impacts  identified  during  the 
analysis  of  the  sample  timber  sale  plan. 

Impacts  to  potential  national  wild,  scenic  or 
recreational  rivers  will  be  further  analyzed  in  the 
environmental  assessments  which  precede  each 
timber  sale.  If  it  is  determined  during  site  specific 
analysis  that  timber  management  actions  could 
adversely  affect  potential  suitability  of  those 
sections  of  the  Umpqua  or  North  Umpqua  Rivers 
as  components  of  the  national  wild  and  scenic 
rivers  system,  BLM  would  consult  with  the 
National  Park  Service  to  develop  appropriate 


mitigation  measures.  There  are  no  clearcut  units  in 
the  sample  5-year  timber  sale  plan  within  one- 
quarter  mile  of  these  river  sections. 

Conclusions 

Visitor  use  increases  or  reductions  may 
occur  in  certain  areas  as  a  result  of  impacts  to 
specific  recreation  experiences.  Alternatives  1  and 
5  would  serve  to  adequately  meet  increasing 
demand  for  motorized  recreational  vehicle  use  and 
some  dispersed  use  areas.  However,  under  these 
alternatives,  demand  associated  with  many  other 
activities  (e.g.,  hunting,  fishing,  watersports  and 
developed  site  use)  would  not  be  met  due  to  a  loss 
of  development  opportunities,  degradation  of  the 
desired  recreation  experience  and  effects  on 
recreation-related  wildlife  populations. 

Alternatives  2,  3,  4,  6,  7,  8  and  9  would  serve  to 
meet  most  recreational  needs.  In  the  long  term, 
however,  elk  population  decreases  under  all 
alternatives  except  6  and  8  are  expected  to  result 
in  lower  hunting  success  and  a  corresponding 
reduction  in  elk  hunter  use.  Under  Alternatives  1,  2 
and  3,  some  fishing  demand  would  not  be  met 
because  declining  fish  populations  are  expected  to 
result  in  a  lower  fishing  success  and  some 
decrease  in  related  angler  use.  A  lower  desirability 
of  BLM-administered  lands  for  fishing  and  elk 
hunting  could  occur. 

The  focus  of  Alternatives  6  and  8  is  on  dispersed 
activities,  natural  areas  and  protection  of 
developed  site  opportunities  in  some  areas.  As  a 
result,  these  alternatives  would  not  be  as 
responsive  as  Alternatives  2,  3,  4,  7  and  9  in 
meeting  demand  for  hiking,  horseback  riding  and 
off-road  vehicle  areas  and  trails. 

Impacts  on  Cultural 
Resources 

Complete  area-wide  field  surveys  of  the  SYUs 
to  identify  cultural  sites  have  not  been  undertaken. 
However,  complete  cultural  resource  surveys  will 
precede  each  specific  timber  management  action 
that  would  result  in  ground  disturbance  or  transfer 
of  title  (BLM  Manual  8100,  Cultural  Resource 
Management).  Under  all  alternatives,  significant 
sites  identified  during  these  surveys  would  be 
protected  in  accordance  with  the  National  Historic 
Preservation  Act  of  1966  and  Executive  Order 
1 1593,  as  stated  in  the  Code  of  Federal 
Regulations  (36  CFR  Part  800). 

Cultural  resources  not  identified  by  intensive  field 
survey  could  be  inadvertently  impacted  under  all 
alternatives.  The  potential  for  damage  would  be  a 
function  of  the  alternative's  timber  harvest  level. 
Adverse  impacts  to  such  sites  could  occur  through 
soil  compaction,  soil  movement  and/or  chemical 
alteration  by  fire  or  mixing  of  organic  matter.  Soil 
compaction  and  soil  movement  could  damage 


79 


artifacts  and  disrupt  the  internal  structure  of 
cultural  deposits.  If  sites  are  uncovered,  illegal 
artifact  collecting  could  occur.  A  site's  chemical 
alteration  during  slash  disposal  and  site 
preparation  could  destroy  combustible  items, 
damage  stone  artifacts  and  contaminate  carbon  14 
dating  samples,  making  them  unreliable  for 
scientific  analysis. 

The  potential  for  damage  from  timber 
management  activity  to  undiscovered  sites  would 
be  greatest  under  Alternative  1  and  least  under 
Alternative  8.  In  a  worst  case,  impacts  would 
completely  obliterate  a  site's  remains.  The 
potential  for  impacts  would  also  be  greater  in 
areas  of  relatively  high  site  density  (e.g.,  Cow 
Creek,  Camas  Valley,  Honey  Creek-Susan  Creek, 
Little  River-Wolf  Creek,  Myrtle  Creek,  South 
Umpqua  and  White  Rock-Dompier). 

Road  construction  would  provide  additional 
access  to  known  cultural  sites,  resulting  in 
increased  visitation.  Vandalism,  theft  and  site 
erosion  could  result.  Esthetic,  recreational, 
interpretive  and  educational  qualities  of  the  sites 
could  be  degraded.  Road  construction  and/or 
timber  removal  on  slopes  above  sites  could  result 
in  increased  rates  of  erosion  and  soil  slumpage 
onto  sites.  These  adverse  impacts  would  be  most 
likely  under  Alternative  1  and  least  likely  under 
Alternative  8. 

The  landscape  and  vegetation  surrounding  a 
cultural  site  may  be  impacted  by  timber  harvesting 
and  road  construction.  Such  impacts  could  reduce 
the  site's  esthetic  appeal  for  recreation, 
interpretation  and  education.  Impacts  to  the  visual 
settings  of  cultural  sites  would  be  most  likely 
under  Alternative  1  and  least  likely  under 
Alternative  8.  Analysis  indicates  that  the  potential 
exists  for  visual  setting  impacts  as  a  result  of 
timber  sales  proposed  in  the  sample  5-year  timber 
sale  plan.  Site  specific  analyses  of  sales  will  be 
included  in  the  environmental  assessments  which 
precede  each  timber  management  action.  Should 
potential  impacts  to  a  site's  setting  integrity  be 
identified,  design  art  techniques  and  other 
constraints  may  serve  to  mitigate  adverse  impacts. 

Conclusions 

Appropriate  measures  would  be  taken  to 
identify  and  protect  cultural  sites  prior  to  ground- 
disturbing  activities  under  all  alternatives. 
Undiscovered  cultural  sites  would  be  susceptible 
to  damage  from  artifact  breakage  or  destruction, 
displacement  of  materials  and  contamination  of 
organic  matter.  Once  a  site  is  found,  however, 
mitigation  measures  would  be  taken  to  minimize  or 
avoid  future  damage.  Under  all  alternatives, 
significant  sites  identified  before  logging  would  be 
managed  to  protect  scientific  and/or  interpretive 
values. 


Impacts  on  Visual 
Resources 

Most  timber  management  practices  disrupt  the 
land  surface,  change  vegetative  patterns,  alter 
species  composition,  and  thereby  create  visible 
contrasts  (see  Glossary)  in  the  landscape. 
Assessing  contrast  for  a  proposed  activity  can 
indicate  the  severity  of  impact  and  help  identify 
mitigation  measures  to  reduce  the  contrast  and 
meet  VRM  class  objectives  for  an  area  (BLM 
Manual  8440).  Environmental  assessments  will 
address  site  specific  visual  impacts  and  apply  the 
Bureau's  contrast  rating  system  (see  Glossary)  to 
specific  timber  management  actions.  The  severity 
of  an  impact  on  visual  resources  depends  on  such 
factors  as  landscape  elements;  location,  number, 
size  and  shape  of  clearcut  units;  location  and 
design  of  roads;  yarding  methods;  amount  and 
treatment  of  debris;  and  success  of  vegetative 
reestablishment  in  disturbed  areas. 

Visual  resource  management  (VRM)  classes 
shown  in  Figure  2-3  were  based  on  an  inventory 
and  evaluation  of  the  area's  scenic  quality, 
sensitivity  and  distance  zone  (see  Glossary). 
During  the  land  use  planning  process,  VRM 
classes  as  described  in  Chapter  2  may  be  changed 
to  resolve  conflicts  between  visual  and  other 
resources  (BLM  Manual  8411).  Upgrading  an 
area's  recommended  VRM  class  would  provide 
adequate  scenic  value  protection  and  result  in 
beneficial  impacts.  Downgrading  VRM  classes 
increases  the  potential  for  adverse  visual  impacts. 
As  an  example,  an  area  in  the  affected 
environment  recommended  as  VRM  Class  II  but 
subsequently  managed  as  Class  III  or  IV  would 
receive  less  protection.  Consequently,  the  long- 
term  effect  of  downgrading  might  be  to  lower 
scenic  quality  in  downgraded  and  adjacent  areas 
even  though  the  Bureau's  ability  to  affect  an  area's 
overall  scenic  quality  is  often  limited  by 
intermingled  land  ownership  patterns  (see  Figure 
1-1).  In  some  cases  the  impacts  of  BLM  timber 
management  activities  would  be  consistent  with 
those  on  surrounding  areas  and  would  not  create 
significant  contrasts,  but  could  tend  to  compound 
the  degree  of  contrast  by  enlarging  the  scale  of 
modification. 

Table  3-12  gives  total  acreage  for  each  VRM  class 
by  alternative.  Under  Alternative  8,  visual  resource 
conditions  (scenic  quality)  would  improve. 
Adverse  visual  impacts  in  highly  scenic  and 
sensitive  areas  would  not  occur  or  would  be 
mitigated.  Under  Alternative  6,  most  highly  scenic 
and/or  sensitive  areas  would  be  protected  with 
slight  adverse  impacts  occurring  along  some 
county  roads,  portions  of  the  South  Umpqua  River, 
Little  River,  Rock  Creek  and  Cow  Creek  drainages 
and  public  lands  in  the  viewsheds  of  some  rural 
residential  areas. 


80 


Table  3-12  VRM  Classes  by  Acreage 


VRM 

Affected 
Environment1 

ALTERNATIVE 

Class 

1 

2,3,4,7,9 

5 

6 

8 

I 

30 

30 

30 

30 

30 

30 

II 

75,700 

2,400 

9,300 

1,100 

26,600 

75,700 

III 

22,900 

400 

13,600 

3,000 

22,400 

22,900 

IV 

325,370 

421,170 

401,070 

419,870 

374,970 

325,370 

Total 


424,000 


424,000 


424,000 


424,000 


424,000 


424,000 


1  VRM  class  acreage  as  recommended  through  the  visual  resource  inventory  and  evaluation  of  the  existing  environment  (see  Figure  2-3) 


Table  3-13  Potential  Impacts  of  the  Sample 

Five-Year  Timber  Sale  Plan  on 

Visual  Resources 

Clearcut 

Scenic 

Sensitivity 

Units 

VRM  Class1    Area 

Quality2 

Level3 

Within  Area4 

II             Olalla  Creek 

B 

H 

5 

Olalla 

B 

H 

1 

Cow  Creek  Road  to  Peck 

B 

H 

7 

Riddle 

C 

H 

7 

Garden  Valley/Lookingglass 

B 

H 

6 

Tenmile 

B 

H 

2 

Berry  Creek  Reservoir 

A 

H 

4 

Camas  Valley 

B 

H 

15 

Highway  38  (Pass  Creek  to  Safley) 

B 

H 

3 

Coles  Valley 

A 

H 

2 

Main  Umpqua  River 

A 

H 

5 

Pleasant  Valley  and  I-5 

B 

H 

5 

Divide  to  Scotts  Valley 

B 

H 

2 

Putnam  Valley 

B 

H 

2 

Canyonville  to  Azalea 

B 

H 

7 

Riddle-Cow  Creek  Valley 

B 

H 

14 

Milo  to  East  Boundary 

B 

H 

3 

Milo  to  Days  Creek 

B 

H 

10 

Canyonville  to  Days  Creek 

B 

H 

1 

South  Myrtle  Creek  Drainage 

B 

H 

10 

North  Myrtle 

B 

H 

5 

Dole 

B 

H 

6 

Wolf  Creek  Falls 

A 

H 

1 

Red  Pond 

A 

H 

4 

Little  River 

B 

H 

12 

Glide 

B 

H 

3 

North  Umpqua  River,  Rock  Creek 

to  Boundary 

A 

H 

5 

Lower  Rock  Creek  to  Rock  Creek 

Campground 

B 

H 

12 

III             Reston 

B 

M 

4 

Drain-Yoncalla 

C 

M 

9 

Elkhead 

B 

M 

5 

Windy  Gap  (Smith  River  Road) 

B 

M 

3 

Smith  River 

B 

M 

9 

South  Myrtle  Creek  Drinage 

B 

M 

2 

North  Myrtle 

B 

M 

3 

Buckhorn  Road 

B 

M 

2 

Cavitt  Creek 

B 

M 

12 

Driver  Valley 

B 

L 

7 

Camas  Swale  and  East  Sutherlin 

C 

M 

5 

Nonpareil 

B 

M 

4 

'  Recommended  VRM  class  based  upon  an  inventory  and  evaluation  of  the  existing  environment  (see  Figure  2-3) 

;  Scenic  quality  (see  Glossary)  is  keyed  as  A-high,  B-moderate  or  C-low 

3  Sensitivity  levels  (see  Glossary)  are  keyed  as  H-high,  M-moderate  or  L-low. 

'  All  potential  impacts  listed  would  be  in  the  FM-foreground/middleground  distance  zone  (see  Glossary) 

81 


Adverse  visual  impacts  under  Alternatives  2,  3,  4,  7 
and  9  would  be  low  to  moderate.  Many  highly 
scenic  and/or  sensitive  areas  would  be  protected. 
Attempts  would  be  made  to  mitigate  adverse 
impacts  on  all  public  lands.  Protection  would  be 
afforded  all  State  of  Oregon  designated  scenic 
corridors  (e.g.,  North  Umpqua  Highway  138, 
segments  of  Highways  42,  227  and  Interstate  5), 
essential  bald  eagle  habitat  and  recreation  sites. 
Under  Alternative  7  the  intensive  timber 
production  base  would  be  72,128  acres  less  than 
under  Alternatives  3  and  4  and  99,388  acres  less 
than  under  Alternative  2.  The  withdrawal  of  this 
acreage  would  result  in  a  lower  level  of  timber 
harvest  and  consequently  fewer  impacts  to  visual 
resources  than  under  Alternatives  2,  3,  4  and  9. 

Under  Alternatives  1  and  5,  adverse  visual  impacts 
would  be  high.  Some  protection  would  be 
provided  for  certain  highly  scenic  and/or  sensitive 
areas,  primarily  essential  bald  eagle  habitat  and 
existing  recreation  sites. 

Table  3-13  summarizes  the  potential  visual  impacts 
of  the  Original  Proposed  Action's  sample  5-year 
timber  sale  plan.  The  table  identifies  the  number  of 
clearcut  units  in  recommended  VRM  class  II  and 
III  areas.  The  potential  for  impacts  would  be 
greatest  in  foreground-middleground  areas  with 
high  scenic  quality  and  high  sensitivity.  Following 
application  of  the  contrast  rating  system, 
necessary  mitigation  measures  would  be 
identified.  Depending  upon  VRM  class  objectives, 
possible  mitigation  measures  under  all  alternatives 
except  1  include  manipulating  the  size  and  shape 
of  clearcut  units,  partial  cutting,  longer  harvest 
cycles  (see  Table  1-3),  screening  with  buffer  strips, 
hydromulching  road  cuts  and  fills,  complete  debris 
disposal,  replanting  with  a  conifer  mixture  and 
other  special  techniques.  Visual  resources  along 
some  streams  with  high  scenic  quality  and/or 
sensitivity  may  be  adversely  impacted  since  all 
alternatives  except  6,  8  and  9  result  in  buffer  entry 
for  some  timber  harvest  (see  Table  3-5  and 
Appendix  C,  Table  C-4). 

The  adverse  visual  impacts  of  herbicide  use  would 
go  unmitigated  and  would  occur  under  all 
alternatives  except  Alternative  7.  In  the  short  term, 
vegetation  sprayed  with  herbicides  would  create 
highly  visible  contrasts.  In  the  long  term, 
vegetative  variety  would  be  reduced  as  herbicides 
encourage  conifers  at  the  expense  of  other 
vegetation  of  high  visual  interest.  Herbicides  used 
on  tall  broadleaf  species  (madrone,  oak,  alder) 
cause  long-term  impacts  of  up  to  20  years  or  until 
the  dead  vegetation  is  over-topped.  Under  all 
alternatives  except  7  and  8,  the  impacts  of 
herbicide  use  would  be  greater  than  under  the 
existing  situation  (see  Impacts  on  Vegetation). 


Impacts  on  Areas  of  Critical 
Environmental  Concern 

Area  of  Critical  Environmental  Concern 
(ACEC)  designation  would  improve  management 
focus  and  provide  guidelines  to  help  achieve 
protection  of  important  and  relevant  resource 
values.  The  alternatives  vary  in  levels  of  ACEC 
designation.  Some  of  the  potential  ACECs  are  also 
designated  or  proposed  for  other  protective 
designation  (see  Table  2-14). 

Under  Alternatives  6  and  8,  seven  areas  (3,100 
acres)  would  be  designated.  Under  Alternatives  2, 
3,  4,  7  and  9,  four  areas  (2,100  acres)  are  identified 
for  ACEC  designation.  Of  the  remaining  three 
areas,  two  are  currently  designated  Research 
Natural  Areas  (RNA)  and  one  is  proposed  for  RNA 
designation.  Alternative  1  calls  for  ACEC 
designation  in  four  areas  (600  acres).  Alternative  5 
has  no  provision  for  designation  of  ACECs. 

Table  3-14  identifies  the  level  of  ACEC  designation 
and  potential  impacts  to  each  area  by  alternative. 

Analysis  of  the  sample  5-year  timber  sale  plan 
indicates  no  sales  would  adversely  impact  those 
areas  qualified  for  ACEC  designation. 

Impacts  on  Special  Areas 

Table  3-15  summarizes  the  potential  impacts 
to  areas  with  values  which  may  warrant  their 
designation  as  Research  Natural  Areas, 
Outstanding  Natural  Areas  or  Environmental 
Education  Areas.  Myrtle  Island  and  Beatty  Creek 
are  currently  Research  Natural  Areas  and  would 
not  be  adversely  impacted  under  any  alternative. 

Alternative  1  allows  for  designation  of  those  areas 
which  would  not  affect  the  commercial  timber 
production  base  of  the  SYUs.  Alternatives  2,  3,  4,  7 
and  9  allow  for  designation  of  those  areas 
identified  as  having  significant  natural  values  for 
science,  recreation  or  education.  Alternative  5 
provides  no  additional  natural  area  designation. 
Alternatives  6  and  8  emphasize  the  study  and 
designation  of  natural  areas.  However,  some  sites 
(e.g.,  Red  Pond,  Dompier  Creek  Landslide)  with 
natural  or  environmental  education  values  may  be 
adversely  impacted  if  they  are  not  designated  or 
do  not  receive  other  protective  management. 

Analysis  of  the  sample  5-year  timber  sale  plan 
indicates  that  no  areas  with  known  or  suspected 
natural  values  would  be  impacted. 

Impacts  on  Energy  Use 

Table  3-16  indicates  the  annual  energy 
investment  required  by  alternative,  as  expressed  in 
British  thermal  units  (Btu's  -  see  Glossary). 


82 


Table  3-14  Potential  Impacts  to  Areas  Qualified  for  ACEC  Designation 


ALTERNATIVE 


Area   Qualified   for 
ACEC  Designation 

1.  Brad's  Creek 

2.  Golden  Bar 

3.  North  Umpqua  River 

4.  Tater  Hill 

5.  Myrtle  Island  RNA 

6.  Beatty  Creek  RNA 

7.  North  Myrtle  Creek 
(Slideover) 

Total  ACEC  Acreage  by 
Alternative 


1 

2,3,4,7,9 

5 

6,8 

0 

0 

_ 

0 

0 

0 

- 

0 

- 

0 

- 

0 

- 

01 

- 

0 

0 

0 

0 

0 

0 

0 

0 

0 

- 

01 

- 

0 

600 


2,100 


3,100 


0  =  No  impact    -  =  Adverse  impact 

'  Area  is  proposed  for  Research  Natural  Area  designation  which  would  protect  the  area's  significant  resource  values. 

Table  3-15  Potential  Impacts  to  Special  Areas 


Potential 

Area 

Designation1 

Tater  Hill2 

RNA 

North  Myrtle  Creek2 

RNA 

(Slideover) 

Woodruff  Canyon  Lands 

RNA 

Old  Fairview 

RNA 

Little  River  Arch 

ONA 

Red  Pond 

EEA 

Dompier  Creek  Landslide 

ONA 

ALTERNATIVE 


2,3,4,7,9 

0 
0 

0 
0 
0 
0 


0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

- 

0  =  No  impact  -  =  Adverse  impact 

'  Key  for  potential  designation:  RNA  -  Research  Natural  Area,  ONA  -Outstanding  Natural  Area,  EEA  -  Environmental  Education 

Area. 

7  Impacts  to  this  area  are  further  examined  in  the  preceding  section  on  Impacts  to  Areas  of  Critical  Environmental  Concern. 


It  is  assumed  that  all  energy  consumed  would  be 
in  the  form  of  fossil  fuels  or  derivatives,  and  any 
energy  investment  would  constitute  an 
irretrievable  reduction  of  world  supplies  of 
petroleum-derived  energy.  The  majority  of  energy 
consumed  is  attributable  to  road  development  and 
care  and  log  production  (all  actions  taken  to 
harvest  trees  and  get  logs  to  the  mill). 

If  the  716  billion  Btu's  attributable  to  the  New 
Preferred  Alternative  were  all  expended  in  the  form 
of  gasoline,  it  would  equate  to  5.7  million  gallons 
or  about  0.4  percent  of  the  1.3  billion  gallons  of 
gasoline  consumed  in  Oregon  in  1980.  This  energy 
investment  is  insignificant  if  compared  to  the 
projected  1980  Oregon  total  of  581  trillion  Btu's 
(Oregon  Department  of  Energy  1980). 


Impacts  to  Human  Health 

The  possibility  of  human  health  being 
impacted  by  the  use  of  herbicides  is  related  to  the 
toxicity  of  the  herbicide,  the  likelihood  of  exposure 
and  resulting  dosage  received  (Norris  1975).  While 
there  are  no  chemicals  that  are  non-toxic,  a 
substance  of  moderate  or  high  toxicity  may 
represent  no  significant  hazard  if  exposure  is  very 
low,  just  as  a  relatively  non-toxic  agent  may  be 
harmful  if  exposure  is  extensive  and  long  term. 
Herbicides  proposed  for  use  in  the  SYUs  are  given 
in  Table  1-4  and  their  toxicities  and  activities  are 
given  in  Table  3-17. 


83 


Table  3-16  Estimated  Annual  Energy  Consumption 

ALTERNATIVE 

12             3             4             5             6             7 

Energy  Consumption 

(Billion  Btu's)                                         834         770         741         723         528         536         514 

8 

218 

9 

716 

Table  3-17  Herbicide  Toxicity 

Common 
Name 

Acute  Toxicity 
LD501              Commonly  Used 
(Rats)                      Term2 

Activity  in 
the  Soil 

No  Effect 

Level  Dose 

in  (mg/Kg/day) 

Tolerances  for 

Residues  in  or 

on  Foodstuffs 

(40  CFR  Part  180) 

Asulam 
(Asulox) 

8,000  mg/kg 

practically 
non-toxic 

short  persistence— 
half-life  6  to  14  days. 

(not  available) 

100  ppb 

Atrazine 

3,080  mg/kg 

slightly  toxic 

absorbed  on  muck 
or  clay — remains  in 
1  foot  of  soil. 

200 
(Reproductive3) 

20-250  ppb 

2,4-D 

300-1,000 
mg/kg 

moderately  toxic 
to  slightly  toxic 

leached  in  sandy 
soils,  breakdown 
depends  on  microbial 
activity. 

20  (Reproductive) 
20  (Teratogenic4) 

100-500  ppb 

Dalapon 
(Dowpon) 

7,570  mg/kg 
(female) 
9,330  mg/kg 
(male) 

practically  non- 
toxic 
500  (Teratogenic) 

leaches  readily  in 
soil,  breakdown  rapid 
and  complete. 

50-150 
(Reproductive) 

100-10,000  ppb 

Fosamine 
(Krenite) 

24,400  mg/kg 

relatively 
harmless 

rapid  degradation- 
very  little  movement. 

60  (Reproductive) 
600  (Teratogenic) 

(non  listed) 

Glyphosate 
(Roundup) 

4,320- 
4,900  mg/kg 

slightly  toxic 

strong  absorption- 
very  little  or  no 
leaching. 

30  (Reproductive) 
30  (Teratogenic) 

100-6,000  pbb 

Hexazinone 
(Velpar) 

1,690  mg/kg 

slightly  toxic 

half-life  2  to  6 
months  in  silt  loams. 

60  (Reproductive) 
300  (Teratogenic) 

100-200  ppb 

Picloram 
(Tordon) 

8,200  mg/kg 

practically 
non-toxic 

sorption  by  organic 
matter  and  clays, 
may  leach  in  sandy 
soils. 

80-150 

(Reproductive) 
1,000 
(Teratogenic) 

50-500  ppb 

Triclopyr 
(Garlon) 

2,140- 
2,830  mg/kg 

slightly  toxic 

possible  leaching, 
half-life  of  46  day. 

30  (Reproductive) 
200  (Teratogenic) 

(non  listed) 

'  LD50  (Lethal  Dose  50)  is  the  dose  of  a  substance  that  is  fatal  to  50  percent  of  the  test  animals.  Also  known  as  median  lethal  dose. 

2  Moderately  toxic  is  50-500  mg/kg,  slightly  toxic  is  500-5,000  mg/kg;  practically  non-toxic  is  5,000-15,000  mg/kg;  relatively 
harmless  is  more  than  15,000  mg/kg  in  a  single  oral  dose  to  rats 

3  The  highest  dosage  level  at  which  no  effects  have  been  observed  in  test  animals  including  loss  of  skin,  hair,  reduced  litter  size,  or 
general  lethal  toxicity 

4  Fetus  malformations  during  development,  not  associated  with  genetic  change. 

84 


In  general,  exposure  of  humans  to  herbicides  can 
occur  in  two  ways:  directly,  by  occupational 
means,  or  indirectly  by  environmental  means.  The 
number  of  persons  that  could  be  affected  by 
herbicide  application  in  the  EIS  area  is  very  small. 
Planned  application  techniques  have  been  shown 
to  effectively  reduce  or  prevent  spray  from  drifting 
onto  streams  and  water  bodies.  Posting  of  sprayed 
areas  should  effectively  minimize  involuntary 
exposure  to  forest  users. 

All  herbicides  proposed  for  use  in  the  RSYUs  are 
registered  with  the  Environmental  Protection 
Agency  (EPA).  Extensive  studies  of  the  absorption, 
distribution,  metabolism  and  excretion  of 
herbicides  in  animals  have  shown  that  herbicides 
and  their  metabolites  are  rapidly  eliminated  from 
tissues  of  most  animals  (including  humans)  and 
thus  do  not  accumulate  to  harmful  levels 
(Eligehausen  et  al.  1980,  Lavy  et  al.  1982,  Leng  et 
al.  1982,  Nash  et  al.  1982,  Newton  and  Norris  1968, 
Norris  et  al.  1974,  Sikka  et  al.  1977,  and  Wolfe 
1976).  There  is  no  evidence  of  carcinogenic  effects 
for  any  of  the  herbicides  listed  in  Table  3-17.  With 
respect  to  2,4-D,  Picloram,  Glyphosate,  Atrazine 
and  Fosamine,  some  additional  direct  data  are 
needed  to  assure  certitude.  The  laboratory 
dosages  at  which  potential  reproductive  effects 
have  been  detected  or  at  which  carcinogenic  and 
mutagenic  effects  have  been  sought  are  much 
greater  in  concentration  and  duration  than  any 
exposure  that  could  occur  in  the  forest  as  a  result 
of  vegetation  control  treatments.  Because  of  the 
limited  toxicity  of  the  herbicides  and  the  low 
potential  for  exposure,  the  likelihood  of  an  adverse 
impact  on  human  health  is  negligible. 

Impacts  on  Socioeconomic 
Conditions 

The  socioeconomic  impacts  are  presented  here 
for  two  different  bases  as  a  means  of 
differentiating  between  the  effects  of  potential 
timber  management  programs  on  existing 
socioeconomic  conditions  and  their  effects  on  the 
conditions  expected  to  occur  if  the  current  timber 
management  program  were  continued.  The 
program  manager  must  know  how  future 
conditions  would  be  affected  if  the  program  were 
changed.  The  public  is  generally  most  concerned 
with  how  future  conditions  would  differ  from 
existing  conditions.  The  impacts  are  presented 
mainly  in  table  form,  as  changes  measured  from 
the  existing  condition  and  as  changes  measured 
from  the  no  action  condition— the  condition 
expected  if  the  current  program  were  continued. 
The  average  12-month  harvest  from  the  Roseburg 
District  from  1976  to  1980  was  187.5  MM  bd.  ft. 
This  recent  experience  is  the  baseline  labeled  the 
existing  condition.  The  no  action  alternative,  201 
MM  bd.  ft.  per  year,  is  the  level  which  would  have 
prevailed  if  the  decadal  allowable  harvest  (2,010 
MM  bd.  ft.)  had  been  sold  and  harvested  in 


constant  annual  increments.  The  average  level  of 
actual  sales  for  1976-1980  was  197.1  MM  bd.  ft. 
and  for  1972-1975  was  208.9  MM  bd.  ft. 

Table  3-18  shows  projections  representing  average 
local  employment  and  earnings  potential  of  timber 
sales  under  all  alternatives  during  the  first  decade 
after  implementation.  Impacts  on  employment  and 
earnings  would  be  phased  in  over  a  period  of  2  or 
3  years  due  to  the  customary  time  lag  between 
sale  and  harvest.  Impacts  on  receipts  distribution 
would  be  delayed  an  additional  year.  The 
projections  represent  the  local  employment  and 
earnings  which  would  be  realized  if  the  annual 
volume  sold  under  each  alternative  is  promptly 
harvested  and  processed. 

While  it  is  anticipated  that  labor  productivity  will 
increase  in  future  years,  leading  to  fewer  jobs  per 
unit  of  primary  timber  processed  (Wall  and  Oswald 
1979).  In  order  to  simplify  impact  estimates,  they 
have  not  been  adjusted  to  reflect  productivity 
changes.  The  effect  of  this  simplification  is  to 
overstate  the  impacts  on  employment  and 
earnings  by  about  10  percent  in  the  short  term, 
and  by  greater  amounts  in  the  long  term. 

Tables  3-19  and  3-20  focus  on  the  impacts  each 
alternative  is  projected  to  have  on  public  revenue. 
Recently,  Roseburg  District's  timber  sale  program 
has  experienced  wide  swings  in  bid  prices  for 
stumpage.  For  example,  in  FY  1981  the  average 
price  of  timber  sold  was  $260  per  M  bd.  ft.; 
however,  in  FY  1982  the  district  recorded  an 
average  sale  price  of  $94  per  M  bd.  ft.  Given  this 
volatility,  tables  3-19  and  3-20  array  possible 
impacts  on  public  revenue  against  two  baseline 
harvest  levels  and  two  levels  of  receipts.  If  FY  1981 
sale  values  are  the  average  for  period  1984  - 1993, 
then  average  annual  disbursements  to  O&C 
counties  from  the  SYUs  are  projected  to  range 
from  $36.2  million  in  Alternative  1  to  $10.5  million 
in  Alternative  8  (Table  3-19).  When  compared  to 
the  no  action  condition,  Douglas  County  receipts 
from  the  harvest  of  timber  on  O&C  lands  in  the 
Roseburg  District  could  decline  by  $.5  million  in 
Alternative  1  or  by  as  much  as  $2.5  million  in 
Alternative  8,  if  FY  1982  sales  values  are  the 
average  for  the  next  10  years.  The  average  annual 
disbursement  of  severance  tax  receipts  from 
CBWR  lands  to  seven  tax  districts  in  Douglas 
County  is  projected  to  range  from  $122,100  in 
Alternative  1  to  $35,500  in  Alternative  8,  if  FY  1981 
sales  conditions  prevail.  Again,  compared  to  a 
maintenance  of  the  no  action  level,  Alternative  1 
would  yield  an  average  annual  decline  in 
severance  tax  receipts  of  $7,200  while  Alternative  8 
would  yield  $38,500  less  if  the  district  only 
averages  $94  per  M  bd.  ft.  over  the  next  decade. 
Historically,  the  sale  of  timber  on  public  domain 
lands  in  the  Roseburg  District  has  accounted  for 
roughly  1  percent  of  the  district's  total  receipts 
from  the  sale  of  timber.  Assuming  that  percentage 
were  maintained  in  all  alternatives,  Oregon's 


85 


Table  3-18  Short-Term  Impacts  Compared  to  No  Action  (and  Existing) 
Condition  on  Local  Employment  and  Earnings  Related  to  Timber  Harvest 
(Average  annual  amounts  during  first  decade) 

Timber 

ndustry  Employment  (Jobs) 

Total  Employment  (Jobs) 

Total  Earnings 
(Millions  ol  1977  dollars 

Logging  and 

Processing 

Forest 
Management 

Douglas  County 

Total  for 
Regional  Economy 

Dougt 

is  County 

Total  for 
Regional  Economy 

Dough 

s  County 

Total  tor 
Regional  Economy 

Douglas 
County 

No 
Action 

Existing 

No 
Action 

Existing 

No 
Action 

Existing 

No 
Action 

Existing 

Action 

No 
Existing 

Action 

No 
Existing 

Action 

No 
Existing 

Alt    1  (Max   Tbr  ) 
Alt  2  (Emp  Tbr  ) 
Alt  3  (Low  MHS) 
Alt.  4  (OPA) 
Alt  5  (No  Action) 
Alt  6  (HD) 
Alt  7  (No  Herb  ) 
Alt  8  (Full  eco  ) 
Alt.  9(NPA) 

'519 
+389 
♦325 
♦283 

-106 
-148 
-690 

♦271 

(•599) 
(♦469) 
(♦404) 
(•363) 
(+   80) 
(-  27) 
(-  68) 
(-611) 
(♦351) 

♦651 
♦488 
♦407 
•355 

-133 
-185 
-866 
♦340 

(♦751) 
(♦588) 
(♦507) 
(•455) 
(♦100) 
(-  33) 
(-   85) 
(-766) 
(♦440) 

•18 

•  15 

•  11 

•  9 

-  4 

-  5 
-24 

•  9 

(♦21) 
(•16) 
(•14) 
(  +  12) 
(♦   3) 
i-    D 
(-  2) 
(-21) 
(♦12) 

•1.135 

•  851 
+     710 

•  619 

-  232 

-  323 
-1.509 

•  593 

(♦1.309) 
(♦$120) 
(•    884) 
(♦    793) 

I'      17-1) 
(-       58) 
(-     148) 
(-1,335) 
(♦    767) 

•1.514 
♦1.135 
+    946 

•  826 

-  310 

-  430 
-2.012 

•  791 

•1,746) 
♦1,367) 
+  1.178) 
♦1,058) 
•     232) 

-  77) 

-  198) 
-1.780) 
♦1.023) 

•$133 
•S100 
•$8  3 
♦S  7  2 

-$2  7 

-S  38 

$17  7 

♦$6  9 

(♦$15  3) 
(♦$120) 
(+$103) 
(♦$  9  3) 
(•$  20) 
(-$      7) 
(-$   17) 
(-$15  6) 
(♦$  90) 

•$184 
♦S138 
+$11. S 
•$10.0 

-$  3  8 
-$  52 

-$245 
♦$  9.6 

(•$21  2) 
(♦$166) 
(♦$143) 
(+$12  9) 
(•$  28) 
(-$      9) 
(-$2  4) 
(-$21  6) 
(•$124) 

Employment  and 
earnings  dependent  on 
the  No  Action 
(Existing  Condition) 
harvest  level  201 
(187  5)  MMbd  tt/year 

1.186 

(1,106) 

1,487 

(1,388) 

41 

(38) 

2.593 

(2.419) 

3,457 

(3.225) 

$30  3 

($28  3) 

$42  0 

($392) 

Average  of  all  sources 
in  county  and  region 
1977-1980  (Tables  2- 
17  &  2-18) 

8.500 

(8500) 

35.100 

(35.100) 

NA 

(NA) 

35.000 

(35.000) 

246,300       (246.300) 

$493  5 

($493  5) 

$3,073.5 

($3,073.5) 

Percent  of  Roseburg 
BLM  of  county  and 
regional  average  1977- 
1980 

1 4  0% 

(13  0%) 

4  2% 

(4  0%) 

NA 

(NA) 

74% 

(6.9%) 

1  4% 

(13%) 

6  1% 

(57%) 

I   4% 

(1.3%) 

NA  Estimates  of  < 

;ounty  totals  are  not  available. 

annual  receipts  from  public  domain  revenues  from 
the  district  would  vary  from  $30,100  in  Alternative 
1  to  $8,700  in  Alternative  8  under  the  FY  1981  sales 
average  of  $260  per  M  bd.  ft. 

In  comparison  to  a  continuation  of  the  harvest 
levels  which  prevailed  from  1976  to  1980  (existing 
condition),  Alternatives  1  through  5  and  9  all 
increase  employment  and  personal  earnings 
dependent  on  the  harvest  of  timber  from  public 
lands  administered  by  the  Roseburg  District.  In 
contrast,  Alternatives  6  through  8  yield  lower 
levels.  Employment  and  income  changes  related  to 
fishing,  hunting  and  other  recreation  are  expected 
to  be  insignificant  for  the  short  term.  In  the  long 
term,  slight  declines  in  fishing  would  occur  in 
Alternatives  1-3  and  slight  declines  in  hunting 
would  occur  in  all  alternatives  except  6  and  8. 
Relative  to  Alternative  4,  Alternative  3  emphasizes 
current  benefits  at  the  expense  of  increased  timber 
production  beginning  140  years  from  now.  See  the 
Impacts  to  Vegetation,  Conclusions,  discussion. 

Clearcutting  and  the  use  of  herbicides  would 
continue  to  be  controversial  due  to  concerns  of 
some  residents,  particularly  adjacent  landowners, 
about  ecosystem  damage  or  health  damage  as 
opposed  to  the  concerns  of  other  residents  for 
economic  benefits  in  timber  production. 
Alternatives  calling  for  rates  of  clearcutting  higher 
than  under  the  existing  plan  would  be  perceived 


by  some  persons  as  increasing  the  risk  of 
downstream  damage  from  flooding  and  washouts. 
Another  perception  of  some  residents  is  that 
increased  timber  harvest  levels  would  decrease  the 
level  of  low  summer  water  flows.  The  impacts  on 
personal  and  community  concerns  of  specific 
actions  such  as  timber  sales  and  herbicide 
application  would  depend  in  part  on  the  locations 
of  the  activities  as  well  as  on  the  manner  in  which 
BLM  communicates  with  affected  residents. 

As  shown  in  the  survey  cited  in  Table  2-27,  more 
residents  of  southern  Oregon  favor  increased 
timber  production  than  favor  increased  hunting 
and  fishing  or  wildlife  habitat.  Although  the  net 
impact  of  these  concerns  is  difficult  to  assess-- 
depending  on  the  intensity  of  the  concern,  the 
knowledge  of  the  holder  and  the  specific 
alternatives  being  compared—it  is  likely  that  an 
alternative  that  reduced  BLM  timber  sales  would 
not  be  favored  by  a  majority  of  southern  Oregon 
residents.  Concerns  for  economic  welfare  and  its 
relation  to  dependency  on  timber  harvest  have 
undoubtedly  deepened  since  the  survey  as  a  result 
of  the  current  recession. 

Conclusions 

As  noted  in  Chapter  2,  the  regional  economy 
is  tightly  linked  to  wood  products  employment. 
The  currently  depressed  levels  of  employment  in 
that  sector  are  related  to  demand  conditions  in  the 


86 


Table  3-19  Projected  Distribution  of  O&C  Payments  from  SYUs  to  Counties 

by  Alternative 

(Average  annual  disbursements  in  millions  of  dollars,  1984-1993) 

Alt.  1           Alt.  2          Alt.  3 

Alt.  4 

Alt.  5           Alt.  6           Alt.  7           Alt.  8 

Alt.  9 

Max.Tbr.  Emp.Tbr.  Low  MHS 

OPA 

No  Action       HD        No  Herb.   Full  Eco. 

NPA 

Total  O&C  Disbursements1 

Douglas  County              @$  94/M  bd.  ft. 

3.3              3.0               2.9 

2.8 

2.3              2.1               2.0               1.0 

2.8 

@$260/M  bd.  ft. 

9.1               8.4              8.0 

7.8 

6.3              5.7              55               26 

7.8 

All  Oregon  Counties 

receiving  O&C                @$  94/M  bd.  ft. 

13.1             121             11.6 

11.3 

9.1               8.3              8.0              3.8 

11.2 

disbursements                @$260/M  bd.  ft. 

36.2            33.5            32.1 

31.2 

25.2            22.9            22.1             10.5 

31.0 

Change  in  O&C  Disbursements  Compared  to  Existing  Conditions  (187.5  MM  bd.  ft.  per  year)2 

Douglas  Gounty              @$  94/M  bd.  ft. 

-  0.2           -  0.5           -  0.6 

-  0.7 

-   1.2           -   1.4           -   1.5           -   2.5 

-   0  7 

@$260/M  bd.  ft. 

+   5.6          +   4.9          +   4.5 

+  4.3 

+  2.8          +  2.2          +   2.0          -  0.9 

+  4.3 

All  Oregon 

Counties 

receiving  O&C                @$  94/M  bd.  ft 

-    1.1           -  2.1           -  2.6 

-  2.9 

-   5.1           -  5.9           -  6.2           -10.4 

-  3.0 

disbursements                @$260/M  bd.  ft. 

+22.0          +19.3          +17.9 

+  17.0 

+  110          +   8.7          +    7.9           -  3.7 

+  16.8 

Change  in  O&C  Disbursements  Compared  to  the  No  Action  Condition  (201  MM  bd.  ft.  per  year)3 

Douglas  County             (5)5  94/M  bd.  ft. 

-  0.5           -  0.8           -  0.9 

-   1.0 

-   1.5           -    1.7           -   1.8           -   2.8 

-   1.0 

@S260/M  bd.  ft. 

+  5.3          +   4.6          +   4.2 

+   4.0 

+   25          +    1.9          +   1.7           -   1.2 

+   4.0 

All  Oregon 

Counties 

receiving  O&C                 @$  94/M  bd.  ft. 

-  2.1           -  3.1           -  3.6 

-  3.9 

-  6.1           -  6.9           -  7.2           -11.4 

-  4.0 

disbursements                @$260/M  bd.  ft. 

+21.0          +18.3          +16.9 

+  16.0 

+  10.0          +   7.7          +  6.9           -  4.7 

+  15.8 

'  $94/M  bd.  ft.  is  the  average  value  of  tim 

ber  sold  by  the  District  in  FY  1982.  $260/M  bd.  ft.  is  the  average  value  of  timber  sold  by  the 

District  in  FY  1981.  All  calculations  assume  that  in  each  alternative  a  constant  3.6 

percent  of  the  annual  harvest  would  be  from 

CBWRand  PD  land. 

''  The  range  of  projected  total  O&C  disbi 

jrsements  is  contrasted  against  the  existing  conditions  baseline  established  in  table  2-24, 

DEIS.  (187.5  MM  bd.  ft.  per  year  times  96.4%  O&C  times  $157  per  M  bd.  ft.] 

I 

•'  The  range  of  projected  total  O&C  disbursements  is  contrasted  against  the  no  action  condition  harvest  level  times  the  1976-1980 

average  receipts  per  M  bd.  ft.  ($157)  times  percentage  O&C  harvest. 

Table  3-20  Projected  Distribution  of  Severance  Taxes  on  CBWR  Lands  by 

Alternative 

(Average  Annual  Disbursements  in  thousands  of  dollars,  1984-1993) 1-2 


Alt.1 
Max.  Tbr. 

Alt.  2 
Emp.  Tbr. 

Alt.  3 
Low  MHS 

Alt.  4 
OPA 

Alt.5 
No  Action 

Alt.  6 
HD 

Alt.  7 
No  Herb. 

Alt.  8 
Full  Eco. 

Alt.  9 
NPA 

@$94/M  bd.  ft. 
@$260/M  bd.  ft. 

44.1 
122.1 

40.8 
112.8 

39.1 
108.2 

38.0 
105.2 

30.7 
84.9 

28.0 
77.3 

26.9 
74.4 

12.8 
355 

37.7 
104.4 

Change  in  Severance  Tax  Distribution  Compared  to  Existing  Condition 
(187.5  MM  bd.  ft.  per  year) 


@$  94/M  bd.  ft. 

-  3.7 

-   7.0 

-   8.7 

-   9.8 

-17.1 

-19.8 

-20.9 

-35.0 

-10.1 

@$260/M  bd.  ft. 

+  74.3 

+65.0 

+60.4 

+57.4 

+37.1 

+29.5 

+  26.6 

-12.3 

-566 

Change  in  Severance  Tax  Distribution  Compared  to  No  Action  Condition 
(201  MM  bd.  ft.  per  year) 


@$94/M  bd.  ft. 

-   7.2 

-10.5 

-12.2 

-133 

-20.6 

-233 

-24.4 

-38.5 

-13.6 

@$260/M  bd.  ft. 

+  70.8 

+61.5 

+56.9 

+  53.9 

+33.6 

+26.0 

+  23.1 

-158 

+53.1 

'  At  present,  the  district  sells  approximately  5.1  MM  bd.  ft.  of  timber  from  CBWR  lands  each  year.  The  impacts  displayed  in  this  table 
assume  that  the  District  will  continue  to  obtain  roughly  2.5  percent  of  its  annual  cut  from  CBWR  lands.  Property  taxes  paid  would 
not  vary  by  alternative. 

''  The  seven  tax  districts  in  Douglas  County  which  share  the  severance  tax  distribution  are  Douglas  County,  Umpqua  Community 
College,  Douglas  Education  Service  District,  and  the  Oakland,  Camas  Valley.  Winston  Dillard  and  Roseburg  School  Districts.  See 
Table  2-21  for  the  distribution  of  taxes  from  CBWR  lands  in  recent  years. 


87 


national  economy.  Beneath  today's  concerns  are 
projections  for  a  dip  in  wood  products  production 
in  the  1980's  and  1990's  due  to  the  availability  of 
timber.  Alternatives  1  through  4  and  9  increase 
timber  supply  from  the  district  and  therefore  would 
mitigate  dips  in  employment  projected  to  occur 
independent  of  actions  by  BLM.  Alternatives  6 
through  8  reduce  local  timber  supply  and  would 
intensify  the  projected  downturn.  If  timber  job 
losses  were  associated  with  a  mill  closure,  workers 
in  the  core  work  force  would  be  unemployed. 
Older  workers  might  not  be  able  to  obtain  new 
jobs.  The  personal  losses  would  be  great  for  those 
individuals  deprived  of  their  functional  relationship 
to  society. 


89 


Chapter  4  Consultation  and 
Coordination  on  the  Draft 
Environmental  Impact 
Statement 


The  Draft  Roseburg  Timber  Management 
Environmental  Impact  Statement  (Interior  DEIS 
82-27)  was  filed  with  Environmental  Protection 
Agency  and  released  to  the  public  on  June  22, 
1982  and  open  to  comment  until  August  23,  1982. 

A  public  hearing  on  the  draft  was  held  August  18, 
1982  in  Roseburg,  Oregon.  Oral  testimony  was 
presented  by  five  people  in  the  afternoon  session 
and  by  14  people  in  the  evening  session. 

A  total  of  95  letters  were  received  in  response  to 
the  draft  environmental  impact  statement.  These 
are  listed  in  the  order  received  in  the  Response  to 
Written  Comments  section.  Substantive  comments 
were  identified  in  29  letters  and  they,  together  with 
responses,  are  printed  on  the  following  pages. 
Copies  of  all  comment  letters  and  the  hearing 
transcripts  are  available  for  review  in  the  Oregon 
State  Office,  825  N.E.  Multnomah  Street,  Portland, 
Oregon  and  Roseburg  District  Office,  777  N.W. 
Garden  Valley  Blvd.,  Roseburg,  Oregon. 

All  letters  and  hearing  testimony  were  reviewed 
and  considered.  Comments  that  presented  new 
data,  questioned  facts  on  the  adequacy  of  the 
impact  analysis,  or  raised  questions  or  issues 
bearing  directly  on  the  draft  EIS  are  responded  to 
in  this  final  EIS.  Some  persons  both  testified  orally 
and  submitted  written  comments,  resulting  in 
duplication  of  comments.  These  comments  are 
responded  to  in  Response  to  Written  Comments. 


90 

Several  reviewers  made  various  resource 
management  recommendations.  These 
recommendations,  as  well  as  all  public  input,  will 
be  considered  before  the  final  decision  is  made. 

Consultation  and  coordination  also  took  place 
with  many  Federal  and  State  agencies  and  local 
governments.  Most  extensive  were  coordination 
efforts  with  the  following:  USFS,  Umpqua  National 
Forest,  Oregon  Department  of  Forestry,  and 
Oregon  Department  of  Fish  and  Wildlife. 

Response  to  Comments 
Common  Issues 

Five  broad  issues  were  raised  frequently  by 
reviewers.  These  issues  and  responses  to  them  are 
presented  below. 

Common  Issue  1:  Wildlife  impacts  largely  dwell  on 
possible  long-term  effects  and  not  the  period  of 
the  10-year  plan.  Adequate  old  growth  would  be 
available  after  one  decade  not  to  affect 
populations  of  many  wildlife  species  regardless  of 
alternative. 

Response:  The  text  has  been  revised  in  the  FEIS, 
Chapter  3,  Impacts  on  Animals  section,  to  include 
additional  discussion  regarding  short-term 
impacts  on  wildlife. 

Common  Issue  2:  In  this  economic  climate  how 
can  you  be  certain  of  the  indicated  level  of 
funding  necessary  to  implement  the  intensive 
management  practices?  Please  display  a  variety  of 
funding  levels  for  each  alternative. 

Response:  The  district's  choice  of  a  Preferred 
Alternative  is  based  on  factors  other  than  funding 
(see  Appendix  A).  The  following  table  shows 


various  levels  of  budget  and  volume  offered  for 
sale  for  the  Preferred  Alternative  (Alternative  9). 

Common  Issue  3:  The  DEIS  does  not  provide 
sufficient  detail  on  the  level  of  intensive 
management  practices  proposed  for  each 
alternative.  Please  display  this  information  as  well 
as  the  proportion  of  harvest  attributable  to  each 
practice. 

Response:  The  following  table  displays 
contributions  to  the  allowable  cut  associated  with 
each  intensive  management  practice  for 
Alternatives  4  and  9. 

Contribution 
to  Annual  Harvest 


Alt.  4 

Alt.  9 

(OPA) 

(NPA) 

Intensive  Management  Practice 

MM  bd.  ft. 

MM  bd.  ft. 

Intensive  Base 

Harvest  and  Reforestation 

183.0 

183.1 

Precommercial/ 

Commercial  Thinning 

26.0 

26.0 

Fertilization 

12.2 

12.2 

Tree  Improvement 

19.1 

19.1 

Sub  Total 

240.3 

240.4 

Constrained  Base 

Harvest  and  Reforestation 

9.1 

6.3 

Total 

249.4 

246.7 

Alt.  9  (NPA)  at  Varying  Funding  Levels 
(in  thousands  of  dollars) 

Full  Program  With 


Full 

No. 

No.  PCT 

Major  Program  Area1 

Program 

Fert. 

or  Fert. 

Transportation  Systems2 

$1,683.0 

$1,599.9 

$1,422.7 

Timber  Management 

7,120.9 

6,419.5 

5,414.6 

Fire  Management3 

525.1 

499.1 

443.8 

Wildlife 

128.0 

128.0 

128.0 

Soil,  Air,  Water 

100.0 

100.0 

100.0 

Total 

$9,557.0 

$8,746.5 

$7,509.1 

Allowable  Cut  Level  MM  bd.  ft. 

247 

235 

209 

'  Program  areas  directly  related  to  harvesting  or  reforestation  and  growth 

2  This  does  not  include  funding  for  bridge,  road,  and  aggregate  production  projects  handled  through  the  Federal  Highway  Administration. 
Funds  for  these  projects  are  held  at  the  State  Office.  An  additional  $500,000  is  needed  for  these  construction  projects. 

3  Program  areas  directly  related  to  reforestation  and  growth. 


91 


Common  Issue  4:  The  DEIS  does  not  provide 
sufficient  detail  on  forest  production  opportunities 
foregone  by  various  allocations  by  alternative. 

Response:  The  following  table  displays  timber 
volume  foregone  for  each  EIS  alternative  by  land 
use  allocation  category. 


Timber  Volume  Foregone  in  Allocation  Areas 

Million  Board  Feet  Production/Year,  Scribner  (MM  bd.  ft./Yr.) 


El  S 

3 


ALTERNATIVE 

4  5  6 


.5 

.5 

.5 

2.5 


4.0 


.5 

.5 

.9 

2.5 

.5 


4.9 


.5 
.5 
.9 
2.5 
.5 


49 


.5 
.5 
.9 
2.5 
.5 


4.9 


Land  Use  Allocation 
Category 

No  Planned  Harvest  Areas 

Botanical 

Cultural 

Recreation 

Bald  Eagle 

Golden  Eagle  &  Raptor 

Old  Growth  Blocks 

Riparian  Areas 

Sub-Total  Volume  Foregone 

Constrained  Harvest  Areas 

VRM  II 

Bald  Eagle 

Northern  Spotted  Owl 

80-Acre  Blocks 

Old  Growth  Blocks 

Osprey/Heron 

Mid-age  &  Old  Growth- 

Riparian 

Sub-Total  Volume  Foregone 

Minimum  Harvest  Age 
Constraint  on 
Intensive  Base 

No  Use  of  Herbicides, 
Fertilizers  or 
Computed  Genetic  Gain 

Total  Timber  Volume 

Foregone 
Allowable  Cut  Level 

1  Alternative  5  utilizes  the  1970  land  base,  inventory  and  allowable  cut  projections. 

?For  these  alternatives,  mid-age  and  old  growth  allocations  managed  under  modified  area  control  includes:  VRM  II,  Northern  Spotted 
Owl,  and  osprey/heron  habitat. 


3.72 

22.02 

22.0: 

10.4 

10.1 

10.1 

14.1 

32.1 

32.1 

.5 

.5 

.5 

.5 

.5 

.5 

.5 

.5 

1.8 

.9 

2.9 

.9 

2.5 

2.3 

1.0 

.5 

1.9 

0.5 

13.8 

22.8 

20.5 

68.0 

12.2 

38.1 

4.9 

96.6 

16.9 

10.5 

21.6 

1.6 

4.1 

C 

8.0 

14.0 

46.0 

46.4 

1.1 

.7 

54.0 

22.02 
10.1 

60.4 

22. 3: 

67.2 

32.1 

86.8 

22.3 

7.0 


7.0 


4.7 


80.0 


25.6 


7.0 


4 

26 

37 

44 

1 

110 

117 

209 

46 

289 

267 

256 

249 

201' 

183 

176 

84 

247 

92 

Common  Issue  5:  Several  respondents  reacted  to 
data  displayed  in  Table  B-6  of  the  DEIS,  which  is 
shown  below.  Particular  concern  was  expressed 
over  the  magnitude  of  the  district's  average 
management  costs  per  acre  in  the  first  years  of 
reforestation. 


Baseline  Yields,  Costs  and  Revenues 
(MCF,  Dollars  Per  Acre) 


Douglas  Sustained  Yield  Unit 

Full  Intensive  Management  Regime:  Plant  improved  stock,  precommercially  thin  where  needed, 
commercially  thin  at  ages  35  and  55,  fertilize  at  ages  12,  35,  45,  55,  65  and  final  harvest  at  age  75. 


Expected 

Diameter 

Gross 

Logging 

Hauling 

Estimated 

BLM 

Age 

of 

Volume 

of 

Pond  Value 

Revenue 

Cost 

Cost 

Sales  Values 

Management 

t 

Stand 

MCF/Acre 

Harvest 

Per  MCF 

Per  Acre 

Per  Acre 

Per  Acre 

Per  Acre 

Costs 

0 

557  95 

Site  prep  ,  plant,  protect 

1 

50  54 

Replant,  protect 

2 

50  54 

Replant,  protect 

7 

1607 

Release 

12 

1372 

Precommercially  thin  &  fertilize 

35 

361.09 

Commercially  thin  &  fertilize 

45 

71  64 

Fertilize 

55 

361  09 

Commerically  thin  &  fertilize 

65 

71  64 

Fertilize 

75 

28945 

Final  harvest 

'35 

1.068 

10.34 

742  08 

792  54 

88663 

125  16 

-21925 

55 

2.734 

12  78 

914  86 

2501.23 

1310.23 

320  42 

870.57 

75 

9,129 

2042 

1455.85 

13290  46 

1877,12 

1069  91 

10343,41 

35 

1.068 

10,34 

1385  56 

1479.78 

886  63 

125.16 

467,97 

55 

2.734 

1278 

244052 

667239 

131023 

32042 

5041,73 

75 

9,129 

20  42 

554880 

50655  08 

1877.12 

1069  91 

47708  03 

South  Umpqua  Sustained  Yield  Unit 

Full  Intensive  Management  Regime:  Plant  improved  stock,  precommercially  thin  where  needed  at  age 
15,  commercially  thin  at  ages  45  and  65,  fertilize  at  ages  15,  45,  55,  65,  75  and  final  harvest  at  age  85. 


Expected 

Diameter 

Gross 

Logging 

Hauling 

Estimated 

BLM 

Age  of 

Volume 

of 

Pond  Value 

Revenue 

Cost 

Cost 

Sales  Values 

Management 

Stand 

MCF/Acre 

0 

Harvest 

Per  MCF 

Per  Acre 

Per  Acre 

Per  Acre 

Per  Acre 

Costs 

557.95 

Site  Prep  ,  plant,  protect 

1 

50  54 

Replant,  protect 

2 

50  54 

Replant,  protect 

7 

16  07 

Release 

I.' 

137.2 

Precommercially  thin  &  fertilize 

45 

361.09 

Commercially  thin  &  fertilize 

55 

71.64 

Fertilize 

65 

361  09 

Commercially  thin  &  fertilize 

75 

71.64 

Fertilize 

85 

28945 

Final  harvest 

'45 

1.754 

11.58 

829  88 

1455,62 

107509 

20556 

174  96 

65 

2,108 

1374 

98283 

2071.82 

1035.39 

247.05 

789  36 

85 

8.811 

20  40 

1454,43 

1281502 

183344 

103264 

9948  92 

45 

1,754 

11  58 

1852.12 

3248  62 

107509 

20556 

1967.96 

65 

2,108 

13.74 

3078  50 

6489  49 

1035  39 

247  05 

5207  03 

85 

8.811 

20  40 

6626  05 

58382.15 

1833  44 

1032  64 

5551605 

'  Revenues  and  costs  maintained  at  1978-1980  levels 

2  Timber  values  appreciate  1  8  percent  per  year  faster  than  management  costs 


93 


Response:  In  the  scoping  process  a  member  of  the 
public  requested  that  an  analysis  of  the  economic 
efficiency  of  forest  management  practices  be 
made.  This  person  also  requested  that  the  genetic 
yield,  costs  and  revenues  used  in  the  analysis  be 
displayed.  Table  B-6  of  the  DEIS  summarized 
those  data  for  a  hypothetical  average  acre  in  the 
Roseburg  District. 

Arrayed  below  are  the  district's  experienced  costs 
by  treatment,  and  the  derived  average  cost  per 
acre  used  to  calculate  the  baseline  figures  listed  in 
the  table  above.  Treatment  costs  per  acre  were 
based  on  the  district's  contracting  experience  from 
1978-1980.  Each  practice  is  applied  only  to  areas 
needing  treatment.  The  average  cost  per  acre 
regenerated  equals  the  cost  of  the  treatment  times 
the  proportion  of  acres  receiving  treatment. 


Roseburg 
District      Cost  for  the 
Cost  per    Average  Acre 
6 


Age  of 

Acre1 

Table  B-i 

Stand 

Treatments 

1978-1980 

DEIS 

0 

Burning 

$189.28 

161.07 

Scarification 

63.64 

4.86 

Paper  Mulch 

495.72 

13.64 

Herbicide 

63.18 

43.30 

Initial  plant 

115.49 

115.49 

Seed  and 

Seeding 

Cost 

100.30 

100.30 

Artificial 

Shading 

212.62 

59.33 

Protection 

Against 

Big  Game 

269.73 

42.40 

Rodents 

269.73 

13.79 

Livestock 

74.12 

3.77 

Sub  Total 

557.95 

1,  2 

Herbicide 

62.08 

6.96 

Protection 

264.96 

12.52 

Replant  or 

Interplant 

137.27 

21.14 

Seed  and 

Seedling 

Cost 

100.30 

9.92 

Sub  Total 

50.54 

Release 


63.79 


16.07 


'  Includes  district  planning,  contract  preparation  and  administration, 
overhead  and  contractual  costs 


94 


Response  to  Written  Comments 

Each  written  comment  letter  from  individuals, 
organizations  or  agencies  was  assigned  an  index 
number  in  consecutive  order  as  received. 


Letter 

No.  Agency,  Organization  or  Individual 

1.  Rogue  Valley  Council  of  Governments 

2.  USDI,  Bureau  of  Mines 

3.  1000  Friends  of  Oregon 

4.  Oregon  State  Dept.  of  Forestry 

5.  Cheryl  Kolander 

6.  L.J.  Fullerton 

7.  Wildlife  Management  Institute 

8.  Riddle  Laminators  (17  signatures) 

9.  Seek,  Inc.,  Realtors 

10.  Larry  D.  Higbee 

11.  Umpqua  Chapter,  Southern  Oregon 
Resources  Alliance  (SORA) 

12.  Oregon  Wilderness  Coalition 

13.  Dale  S.  Sawyer 

14.  Rodney  F.  Greene 

15.  Umpqua  Valley  Audubon  Society 

16.  Umpqua  Valley  Audubon  Society 

17.  Clifford  M.  Bryden 

18.  Gordon  Thoreson 

19.  L.A.  Kostur 

20.  Umpqua  Dairy  Products  Co. 

21.  Umpqua  Savings  and  Loan 

22.  Commercial  Title  Co. 

23.  Bohemia  Inc. 

24.  Harmony  Farm 

25.  Western  World  Realty,  Inc. 

26.  Thomas  A.  Lawler 

27.  Wayne  Peterman 

28.  Lorraine  Michal 

29.  Champion  International  Corp. 
30  James  A.  Little 

31.  Glide  Lumber  Products  Co. 

32.  USDI,  National  Park  Service 

33.  Richard  Chasm 

34.  Douglas  National  Bank 

35.  Roseburg  Area  Chamber  of  Commerce 

36.  L.L.  Burr  Logging  Co.,  Inc. 

37.  Robert  Dahne 

38.  Mary  Lou  Goodin 

39.  Les  Sanders 

40.  Becky  Nelson 

41.  Barbara  Nelson 

42.  N.  Carlene  and  W.  Rick  Wilkinson 

43.  Umpqua  Community  College 

44.  Sun  Studs,  Inc. 

45.  Lois  J.  Gilbert 

46.  Stuart  Richert 

47.  Weyerhaeuser  Company,  Western 
Oregon  Region 

48.  William  L.  Streitz,  M.D. 


Letter 

No. 

Agency,  Organization  or  Individual 

49. 

Bob  Flynn 

50. 

Ralph  Saperstein 

51. 

Joel  Rosenberg 

52. 

Lloyd  R.  Van  Doren 

53. 

Ronald  V.  Widener 

54. 

Dale  Bonnell 

55. 

Gene  H.  Landout 

56. 

Howard  W.  Johnstone 

57. 

Mark  and  Roberta  Kincaid 

58. 

Roseburg  Lumber  Co. 

59. 

Mark  A.  Lowry 

60. 

Lynda  Oebel 

61. 

Chuck  Kempas 

62. 

The  Neil  Company  Realtors 

63. 

John  Rard 

64. 

Mrs.  T.L.  Suhrstedt 

65. 

James  R.  Fourtner 

66. 

Mrs.  R.J.  Parlik 

67. 

Carolee  Fourtner 

68. 

Douglas  Timber  Operators 

69. 

Association  of  O&C  Counties 

70. 

Ken  Shrum 

71. 

Western  Forest  Industries  Association 

72. 

Wade  Mosby 

73. 

Richard  Mitchell 

74. 

USDI,  Fish  and  Wildlife  Service 

75. 

City  of  Sutherlin 

76. 

William  E.  Markham,  State  Representative, 

District  46 

77. 

Richard  Croucher 

78. 

Harold  F.  Anderes 

79. 

Floyd  G.  Sackett 

80. 

Associated  Oregon  Loggers,  Inc. 

81. 

Jozef  Reynaerts 

82. 

Corey  John  Bidwell 

83. 

North  West  Timber  Association 

84. 

William  C.  West 

85. 

Oregon  Dept.  of  Fish  and  Wildlife 

86. 

U.S.  Environmental  Protection  Agency 

87. 

Ellis  W.  Antrim 

88. 

Marilyn  J.  Smith 

89. 

Duane  L.  Smith 

90. 

USDA,  Forest  Service,  Pacific 

Northwest  Region 

91. 

Industrial  Forestry  Association 

92. 

Cecil  and  Phyllis  Hubbs 

93. 

Cameron  LaFollette 

94. 

USDC,  National  Oceanic  and 

Atmospheric  Administration 

95. 

Oregon  Executive  Dept.,  Intergovernmental 

Relations  Division 

2-1 


United  States  Department  of  the  Interior 

BUREAU  OF  MINES 

WISI IRN   Hill)  OPERA  I  IONS  (  INI  t.K 

I  \si     IGO   )RD  w  h  Nil 

sink  \si  .  \s  \sllls,    I  ms     ,     i 

July   22,   1982 


Memorandum 

To:  James  E.   Hart,  District  Manager,   Bureau  of  Land  Management, 

Roseburg,  Oregon 

From:  Chief,  Section  of  Minerals  Involvement 

Subject:     Draft  Environmental    Impact  Statement  (DEIS)    for  the 
Roseburg  Timber  Management  Plan 

We   found  the  statement  well   written  except  for  lack  of  comments  on  mineral 
resources.     The  proposed  action  is  not  expected   to  adversely  affect  mining   or 
mineral   resource  utilization  in  the  area.     However,  the  disclaimer  on  page  63, 
that  the  proposed  action  will   not   significantly  affect  mineral    resources, 
should  be  preceded  by  at  least  a  brief  discussion  that  describes  the  existing 
mineral    related  activities. 

The  discussion  of  socieconomic   conditions  fails  to  mention  the  strategic 
importance  of  the  only  operating  nickel   mine  in  the  United  States.     This  mine, 
the  Hanna  Nickel   Mine  located  near  Riddle,   in  Douglas  County  should  also  be 
described  briefly  because  of  its'    economic   importance   to  the  local   community. 

Thank  you  for  the  opportunity   to  review  the  draft  statement. 


95 


Response  to  comments  in  Letter  2. 


The  purpose  of  EIS  scoping  is  to  focus  only  on  those  issues  that 
relate  to  significant  effects  of  the  EIS  alternatives    Analysis, 
including  the  scoping  process,    indicated  that  timber  management  would 
not  significantly  impact  mining  or  future  mineral    resource 
utilization.  Therefore,   as  stated  on  page  63  of  the  DEIS,   these 
topics  are  not  discussed. 


D.  P.   Banister 


1000  FRIENDS  OF  OREGON 


400  DEKUM  BUILDING,  519  S  W  THIRD  AVENUE,  PORTLAND.  OREGON  97204  (503)  223-4396 


Response  to  comments  in  Letter  3. 


3-1 


July    19,    1982 


Bureau  of    Land   Management 
Roseburg   District   Office 
777    N.W.    Garden   Valley    Blvd. 
Roseburg,    OR      974  70 

Re :      Roseburg   Timber  Management   DEIS 

To  Whom   It  May   Concern, 

I    am  writing    to  express   concern   over    the   omission   of 
a   discussion   of   certain   recent   studies   by   Dr.    Robert   R.    Curry 
in    the   subsection   entitled    "Impacts   on   Soils"    in   Chapter    3 
"Environmental   Consequences "    at   pages    64-66 . 

Dr.      Curry,    on   the    faculty  of   the   University  of   Cal- 
ifronia,    Santa   Cruz,    testified  before   Congress    in    1971   that 
"[p] resent   evidence    suggests    forest   cutting,    by   any   but    the 
most   conservative    and   careful   methods   appears    to   completely 
defeat    the   nutrient   cycling   and   soil   nutrient   storage   capacity, 
as   well   as    increase   erosion .      Western    forests   may   have    less 
than    200   years   of   productive    fertility   remaining  before   per- 
manent. . .eradication   of   productivity    for   saw    timber  production, 
since    then   Dr.    Curry   has    refined   and   expanded   his   hypotheses 
and   is   chairing   a   National   Academy   of   Science   Study   on   its 
relevance    to   agriculture . 

It    is   distrubing    that   such   a    fundamental    issue    as 
longterm  soil   productivity   should   be    treated    in   such   a 
summary    fashion    that   Dr.    Curry's   work    is   not   cited   once.      Soil 
productivity    is   one   of    the    fixed    limitations   which   should   con- 
trol  the   decisions   concerning   use   of   and   investments    in,    our 
national    forests . 


3-1         The  literature  includes  many  authors  whose  work  has  not  been  cited   in 
the  DEIS.  Although  the  literature  is  not  conclusive,   recent  work  has 
shown  soil  productivity  to  be  affected  as  indicated  on  page  66  of  the 
DEIS 

This  issue  was  also  addressed   in  the  promulgation  of  guidelines  by 
the  92nd  Congress.  Titled  "Clearcutting  on  Federal   Timberlands," 
Report  by  Subcommittee  on  Public  Lands  (commonly  referred  to  as  the 
Church  Report),   this  document  has  been  adopted  by  BLM  as  indicated  on 
page  19  of  the  DEIS. 


RL/cms 


Forestry  Department 

OFFICE  OF  STATE  FORESTER 

260O  STATE  STREET    SALEM.  OREGON  97310     PHONE  3782560 


July  28.  1982 


Mr.  James  E.  Hart,  District  Manaoer 

Roseburg  District 

Bureau  of  Land  Management 

777  N"  Garden  Valley  °!vi. 

Roseburg,  Oregon  97470 

Dear  Mr.  Hart: 

The  Oregon  State  Forestry  Department  has  reviewed  the  Roseburg  Timber 
Management  Draft  Environmental  Impact  Statement.  We  are  pleased  to  note 
the  consistency  of  the  proposed  action  with  the  basic  objectives  of  the 
Forestry  Program  for  Oregon,  especially  with  regard  to  the  production  of 
timber. 

While  we  support  the  direction  of  the  proposed  action  I  am  particularly 
concerned  with  the  need  to  conserve  the  existing  commercial  forest  land 
base  as  an  essential  element  to  offset  projected  timber  supply  shortages 
in  this  Timbershed.  We  would  like  to  offer  comments  in  four  general 
areas  including;  selection  of  an  alternative,  consistency  with  the 
Forestry  Program  for  Oregon,  intensive  management  and  the  scattered  owner- 
ship pattern. 

I  hope  these  comments  will  be  useful  and  I  trust  they  will  be  given  adeguate 
weight  and  consideration  in  the  final  environmental  impact  statement. 


H.  Mike  Miller 
State  Forester 
HMM:jp 
cc:  Board  of  Forestry 

Executive  Staff 

Congressional  Delegation 

Pat  Amedeo 

Tom  Lane 

William  Leavell,  BLM  State  Director 

State  Clearinohouse  (PNRS  #0R  820628-068-4) 


4-1 


Oregon  State  Forestry  Department  Review  of 

Roseburg  District  Timber  Management 

Draft  Environmental  Impact  Statement 


During  our  coordination  effort,  the  Forestry  Department  has  raised  a  number 
of  issues  at  various  Input  stages  In  the  planning  process.  Some  of  these 
concerns  have  been  resolved,  however  we  dre   interested  in  further  discussion 
of  the  following  issues  In  the  EIS. 

Selection  of  an  Alternative: 

Generally  we  support  the  direction  of  the  preferred  alternative  since 
it  provides  a  harvest  level  and  proposed  management  program  comparable 
to  the  "Objective"  level  identified  in  the  1980  Timber  Supply  Assessment 
for  the  Roseburg  Timbershed.   In  brief,  the  Assessment  points  out  that 
while  BLM  is  nresenMy  harveitino  timber  at  a  reasonably  attainable  level 
in  western  Oregon,  overall  harvest  levels  in  most  tlmbersheds  are  ex- 
pected to  decline.  BLM  could  help  alleviate  this  potential  shortfall  by 
increasing  its  present  harvest  by  an  averaae  of  7%  in  western  Oregon. 

Consistency  with  FPFO: 

It  is  the  Board  of  Forestry's  policy  to  promote  a  statewide  Forestry 
Program  for  Oregon  which  meets  certain  objectives:  maintain  the  existing 
commercial  forest  land  base,  maintain  or  increase  the  annual  allowable 
harvest,  utilize  a  full  range  of  intensive  management  practices,  and  main- 
tain community  stability. 

Forestry  has  encouraged  the  BLM  to  be  consistent  where  possible,  with  these 
State  objectives. 

A  table  showing  BLM  harvest  projections  from  the  1980  Assessment  were 
provided  your  office  in  a  memorandum  dated  July  19,  1982.  We  would  like 
to  incorporate  these  harvest  levels  into  the  consistency  table  as  a  bench- 
mark for  comparison  of  community  stability. 

The  reasonably  attainable  harvests  for  the  Roseburg  District  would  be: 

1980     1990     2000     2010     2020 

MMCF  40.3     39.5     39.2     38.8     38.7 


As  you  note,  the  harvests  projected  are  not  constrained  by  an  artificial 
limitation  such  as  non-declining  even  flow,  but  are  in  accord  with  the  prin- 
ciple of  sustained  yield. 

Additionally,  we  feel  some  limited  opportunities  exist  to  increase  this 
harvest  level  in  some  timbersheds  from  a  "surplus  inventory"  or  as  a 
"cooperative  harvest"  target.  This  increased  harvest  is  intended  to  make 
up  for  the  "fall  down"  expected  in  some  timbersheds  to  ease  community 
transition  to  a  sustained  harvest  from  all  owners. 


Intensive  Management: 

In  order  to  rank  alternatives 
Objective  to  maximize  growth 
4  —  2  |Pract'ces-  tne  EIS  should  dis 
I  of  practices  that  are  accompl 
Information  in  the  DEIS  does 
sive  management  practices  in 
of  Proposed  Action  and  Altern 


4-3 


4-4 


types  and  levels  of  treatment 
the  process  of  computer  model 
because  most  of  the  land  base 
in  needed  treatments  currentl 
these  projections  make  meanin 


accordino  to  thei 
through  increased 
play  the  differenc 
ished  and  that  pro 
not  provide  a  basi 
a  comparative  mann 
atives  by  Treatmen 


r  consistency  with  the  FPFO 
intensive  management 
e  between  the  current  level 
posed  for  each  alternative, 
s  by  which  to  measure  inten- 

Table  1-2  titled  Comparison 
First  Decade  displays  the 


as  a  comparison 
ing  acres  tend  to 
over  time  is  cons 
y  and  combinations 
gful  comparisons  d 


with  the  proposed  action.  In 
be  treated  by  percentages  and 
idered  for  treatment,  backlog 
of  treatments  occuring  during 
ifficult. 


In  the  FPFO  consistency  table  our  benchmark  is  to  "implement  a  full  range 
of  intensive  timber  management  practices  for  optimization  of  timber  pro- 
duction". Using  the  information  in  your  table  this  could  be  a  comparative 
target  number  such  as  a  percent  of  the  CFL  land  base  receiving  basic  inten- 
sive management  treatments  during  the  first  decade. 

To  better  provide  a  benchmark  consistency  target,  OOF  suggests  that  you 
display  acres  for  each  of  the  basic  intensive  forestry  practices  implemented 
as  a  percent  of  the  CFL  base  projected  for  each  decade. 

We  estimate  that  35%  of  the  CFL  base  currently  receives  some  intensive 
management  treatment.   (Plant,  Rehb.  Release,  PCT,  CT  and  fertilization). 
The  Preferred  Alternative  would  result  in  about  65%   treated.  Alt.  1,  2 
and  3  are  greater  than  65%  and  Alt.  6,  7,  and  8  are   less  than  Alternative  5 
and  would  be  inconsistant  with  FPFO  in  our  opinion. 

Scattered  Ownership  Pattern: 

One  issue  not  addressed  in  the  DEIS  is  the  checkerboard  pattern  of  ownership 
characteristic  of  0  &  C  lands.  The  operational  problems  due  to  this 
pattern  affect  the  management  programs  for  both  commercial  timber  production 
and  amenity  values.   It  is  uncertain  how  the  objectives  of  programs  for 
visual  resource  and  wildlife  habitat  can  be  implemented  with  uniformity  and 
measured  objectively.  This  problem  needs  to  je  disc-^s?-i  in  cone  details 
in  the  Environmental  Impact  Statement. 


Response  to  comments  in  Letter  4 

4-1     FPFO  forest  harvest  levels  for  the  1980  decade  have  been  incorporated 
by  text  revision  (see  FEIS  Chapter  1  State  and  Local  Governments 
under  Interrelationships  section). 

In  addition,  FPFO  harvest  levels  for  decades  1980  -  2070  are  shown 
below  Volumes  in  MM  bd.  ft.  were  converted  frcm  32-foot  to  16-foot 
log  rule  for  direct  comparison  throughout  the  EIS. 


BLM  Harvest  Projections  -  1980  TSA 
(MMCF  &  MMBF/Yr  jl 
Decade 
BLM  Unit   1980   1990  2000   2010  2020   2030  2040   2050  2060   2070 
Roseburg 

MMCF       40.3   39  5   39.2  38-8   38.7   38. 2   37.7   37.2   37.0   36  7 
MMBF      245.4  235.4   247.1  237.7   208.3  160.8   141.6  161.3   168.7  167.2 


iHarvest  in  each  decade  sustainable  for  seven  additional  decades  in  cubic 
feet  (incremental  even-flow).  Harvest  in  board  feet  is  based  on  16-foot  logs, 
Scribner  Log  Rule.  Converted  by  D.  Preston  (OSO)  8/4/82  frcm  OSDF  original 
submission 


4-2  The  following  tables  sh  Tactices 

i  . 

i  Ac.  Planned  Ac.  Planned 

;  i  ice (1972-1981)*  Alternative  4**       Alternative  9* 

31,866  103,010 


102,197 


68,027 


97 


The  acres  toe  each  intensive  management  practice  planned  for  the 
first  decade  are  shown  in  DEIS,  Table  1-2.  On  the  commercial   forest 
land  base  92.5  percent  of  the  intensive  management  acres  harvested  in 
the  first  decade  will   receive  spacing  control  and  fertilization, 
planting  with  genetically  improved  stock  will  also  occur  on 
approximately  30  percent  of  the  acres  harvested  in  the  first  decade. 
This  would  increase  to  approximately  92.5  percent  by  the  fourth 
decade. 


2,289 


31,076 


40,284 


9,365 

Ac.  A      i  Ac.  Planned 

(1972-1981)*  Alternative  4* 


Ac.  Planned 
Alternative  9* 


14 , J45  40,755  40,449 

Lnning                        1 ,  119  3,479  1,383 

56,029  55,646 

0  15,200  15,200 

146  0  0 

24,964  3,347  3,328 

■       i                                                          wth  Man3jejnent  Camiittee  Report 

:•     L-2 


Other  harvested  acres  would  not  be  subject  to  intensive  timber 
management  practices  that  are  yield  enhancing. 

By  the  fifth  decade  all   intensive  management  practices  would  be 
scheduled  at  maximum  levels.  The  percentage  of  commercial  forest  land 
scheduled  for  each  intensive  management  practice  is  shown  below: 

Percent  Commercial  Forest  Land  Base* 
Scheduled  for  Intensive  Management 
(Fifth  Decade  and  Beyond) 
EIS  Alternative 


2        3  4        5  6       7 

85     79       79     23       53     37 


8     9 
0     78 


Intensive  Mgt. 

Practice 

Spacing  Control 

( Pre .  Carml .  & 

Comml .  Thinning) 

Fertilization 

Tree  Improvement 

•Percent  scheduled  by  practice  (Commercial  Forest  Land  Base  391,070 


M 

85 

79 

79 

0 

53 

0 

0  78 

9] 

85 

79 

79 

73 

53 

68 

0  78 

•)  on  page  82  of  the  DFIS.   BUI  recognizes  the  "ability  to 
-  quality   is  often  1  united  by 

■■ 

ler  the  various  alternatives  also 
i  ownership. 

It   is  not    the   Lnten!  ontrol    or   influence  private  land 

management  decision-,  ■  r  red  or  any  of  the  other 

alternati  k+i  <.>>ntf)i    ■  ,r   influence. 


5-1 


D!  iJT  E.I.S. 


1. 


rile 


5-2 1 


-    ■    ■  . ons,  but  rbther, 

-T.snt   alternatives  must   be  discussed.      In   .specific,   the  alternative 

--vest:     var  >f   sevectlve    -  shelter- 

c  leer  cuttin  .  of  land, 

■  .re    -rees. 

"la  -•  lysis.     Specif]  cally: 

full-sus  ..-.tes. 

2. 

-  er.t  error  in  that  :r.e  NoM 

he  acreage  re. 
:  -s  to  oe  reJuced  I  r«      :ed  siie,  ar.r 

size  p.- ! 

rt  of  tr.e  i.  .  . 


5—3  |  Tnere  .,  assossed  ne 

- 
Lvity,   recreation,   etc.,   must  .lave  cleai 
■    ■    ■  is  pursuant 

11    r-J  ...suroa   ore  ,iCt5  are  too  sevore 

to  alio*  justil  ferred  Alternative,    Eiven  all  applicable  conservation 


the  case  no  i-res   are   u   bo  delineated  and  odooted,   a  j-usti:. 

Ls   must   be  nude.      ..  CFS.    a  worst  case   scenario  sust    be 

developed  and  ox i  isbj  : or  public   scrutiny. 


£^yV^^^ 


Cneryl   Kolander 


98 


Response  to  comments  in  Letter  S. 

5-1  The  public  scoping  process  that  preceded  development  of   the  DEIS 

identified  the  issues  addressed  in  the  EIS  alternatives  as  the  most 
important  and  relevant  for  analysis.  The  EIS  does  address  several 
different  timber  management  options,   including:  no  herbicides,  no 
fertilizer  and  smaller  minimum  harvest  size.  Specific  management 
practices,   including  various  harvest  methods,   are  described  in  the 
BLM  Timber  Management  Final   EIS  1975,  which   is  incorporated  by 
reference.  Alternative  harvest  methods  are  considered  on  a  site  by 
site  basis,   utilizing  the  appropriate  method  to  mitigate  a  potential 
impact. 


In  the  EIS,  Chapter  1  references  the  BI*  Tinb  i  it   Pinal   EIS 

1975,  which  includes  a  detailed  listing  of  mitigating  measures. 
Chapter  1  also  describes  project  design   t ■    .i    ,  ■       -• 
mitigating  measures  feasible  to  implement  without  changing  an 
alternative  or  impacting  the  allowable  cut  associated  with  a 
particular  alternative.  Additional  means  to  mitigate  adverse 
environmental    impacts  are  discussed  in  Chapter  3. 


The  North  Myrtle  proposed  RNA  acreage  is  correct  as  shown  in  the  DEIS 
(Table  2-14).  The  Proposed  RNA  was  reduced  to  approximately  240  acres 
in  the  Original  Proposed  Action  (Alt.  4).  This  protects  an  area 
sufficient  to  meet  RNA  cell   needs  and  sensitive  plant  habitat,  while 
leaving  the  remainder  open  to  other  management  activities.  There  are 
no  minimums  established  for  RNA  size;   some  RNAs  are  80  acres  or  less. 
Note:   the  entire  480-acre  parcel    is  part  of  a  serai  stage  block  in 
the  new  Preferred  Alternative  (Alt.  9). 


DANItl  A   POOIE 

i    K    |AHN 

L-  L.  WILLIAMS!  in 


Wildlife  Management  Institute 

70S  Wire  Building.  lOOOVefmonl  Ave  .  N  W  .  Wash. ngton,  O  C    2000$  •   202 


August  12,  1982 


Mr.  James  E.  Hart 

District  Manager 

Roseburg  District  Office 

Bureau  of  Land  Management 

777  NW  Garden  Valley  Boulevard 

Roseburg,  Oregon  97470 

Dear  Mr.  Hart : 

The  Wildlife  Management  Institute  submits  its  comments  on  ROSEBURG 
TIMBER  MANAGEMENT  ENVIRONMENTAL  IMPACT  STATEMENT,  Oregon.   We  usually  would  say 
we  are  pleased  to  submit  comments,  but  this  time  it  is  a  sad  occasion. 

Your  plan  is  good,  probably  about  the  best  that  could  be  expected 
from  the  lands  in  the  Roseburg  District.   It  is  not  quite  as  good  for  wildlife 
as  the  Coos-Curry  plan.   However,  both  have  now  gone  down  the  tube— negating  the 
many  years  work  to  bring  06.C  lands  under  some  kind  of  multiple  use. 

We  are  referring  to  the  July  15  memo  from  the  Director.   The  third 
paragraph  throws  out  Sikes  Act  and  other  agreements  with  the  state  and  other 
agencies  on  spotted  owls  as  "interim."  It  says  in  part  "Habitat  through  land 
use  allocation  in  these  instances  on  OSC  lands  will  be  provided  only  to  the 
extent  it 


7-1 


es  from  noncommercial  timber  lands." 


This  is  done  at  a  time  when,  in  the  real  world,  some  purchased  timber 
has  stood  uncut  for  over  3  years,  sales  are  down  and  some  timber  offerings  are 
not  being  sold. 

Several  years  ago  a  humorous  sheet  was  circulated  in  Oregon  giving 
a  recipe  for  Roasted  Spotted  Owl.   That  may  no  longer  be  a  joke  since  July  15. 

We  see  no  reason  to  make  our  usual  detailed  analysis  of  the  plan,  as 
it  will  be  completely  changed  by  the  time  the  final  EIS  is  prepared. 

We  do  wish  to  call  your  attention  to  one  important  fact,  however. 
The  423,896  BLM-adminlstered  acres  contain  tracts  of  Public  Domain.   This  land 
is  subject  to  FLPMA.   We  insist  it  be  managed  for  multiple  uses--and  in  this 
case  we  define  those  uses  as  old  growth  since  somewhere  in  the  OSC  mosaic  there 
should  be  a  tree  older  than  rotation  age. 


Mr.  James  E.  Hart 


August  12,  1982 


Perhaps  the  great  need  is  to  repeal  the  O&C  Act,  removing  the  boon- 
doggle Oregon  counties  receive  of  75  percent  of  the  long  time  average  $300,000,000 
a  year  from  timber  sales.   This  diversion  of  federal  funds  still  occurs  at  a  time 
when  our  government  proposes  selling  public  lands  to  retire  the  national  debt. 
The  government  does  not  seem  worried  about  subsidies  to  Western  Oregon  counties 
or  to  the  livestock  graziers  of  the  West. 

We  view  this  action  as  short  sighted  and  a  detriment  to  long-term 
management  of  OSC  lands.   This  reversal  to  single  use  management  will  draw 
attention  to  the  basic  inequities  of  the  OiC  Act  and  hopefully  will  result  in 
its  amendment  or  repeal. 

These  remarks  have  been  coordinated  with  William  B.  Morse,  the  Institute' 
Western  Representative. 


Sincerely,  . — .. 


Daniel  A.  Poole 
President 


DfOIC<\TEDTOWIMUff 


11 


99 


Response  to  oanments  in  Letter  7. 

7-1  The  Bureau  agrees  that  management  of  Public  Domain  (PD)   lands  is 

governed  by  FLPMA.  The  Preferred  Alternative  and  most  other 
alternatives  would  provide  for  management  of  the  Public  Domain  (PD) 
lands  under  multiple  use  concepts.  Due  to  the  small  amount  of  these 
lands,  i  klm  analysis  showed  they  cannot  by  themselves  satisfy  old 
■  objectives  for  wildlife  habitat.  The  PD  lands  in 
m  Oregon  are  combined  with  O&C  lands  for  allowable  cut 
calculation  purposes. 


August    12,    1982 


Mr.    James  Hart 

District  Manager 

Roseburg  District   BLM 

777    N.W.    Garden   Valley  Blvd. 

Roseburg     OR     97470 

Dear  Jim: 

The  Umpqua  Chapter  of  the  Southern  Oregon  Resource- 
to  continue  its  participation  in  the  planning  and  management  &■   I 
of  the  District  by  submitting  our  comments  on  draft  EIS 
Timber  Management  Plan. 

The  goal  of  our  organization  is  to  seek  out  a  balance  in  resource  issues 

that  provides  economic  stability  for  Douglas  County,  while  pro-. 

the  protection  of  the  environment  so  key  to  ma 

life  we  all  enjoy.   Our  membership  and  our  Board  of  Directors  represents 

a  cross-section  of  the  community  from  those  with  strong  resource  utilization 

interests,  to  those  with  strong  concern  for  re  -  environmental 

concerns.  Contrary  to  our  friends  in  either  the  La 

groups  or  the  timber  industry,  we  are  not  single-use  or  objective  oriented. 

Furthermore,  unlike  some  local  advocate  groups,  we  are  aware  of  the 

differences  in  purpose  between  BLM  and  Forest  Service  management.   Indeed, 

we  believe  our  organization  represents  the  "community"  that  the  06C  act 

referred  to  when  it  discussed  providing  for  economic  stability,  watershed 

management,  and  recreational  opportunity. 

In  reviewing  the  activities  leading  up  to  the  draft  EIS 
board  meeting,  one  factor  became  quite  clear.   You  and  youi 
done  an  outstanding  job  of  listening  to  the  public  concerns  and 
demonstrated  a  sincere  concern  for  the  needs  and  desires  of  the  majority 
of  the  local  population.   The  dedication  and  professionalism  demonstrated 
by  you  and  your  staff  is  most  appreciated  by  our  organization. 

In  reviewing  the  EIS  and  recent  planning  criteria  established  by  the 
Bureau,  it  would  appear  that  our  input  is  needed  in  two  areas: 

I.   Contrary  to  other  planning  efforts,  the  proposed  action  can  be 
changed  in  the  final  EIS  to  reflect  Bureau  laws  and  policy  leading  to  the 
actual  decision.   Input  should  therefore  deal  with  what  our  organization 
believes  the  proposed  action  should  be  in  the  final  EIS. 


11-1 


11-2 


II.   The  adequacy  of  the  EIS  in  terms  of  properly  displaying  the 
environmental  and  human  effects  of  various  alternatives. 

During  the  Boards  review  of  the  EIS,  it  became  clear  that  we,  as  lay 
members  of  the  public,  cannot  evaluate  such  technical  items  as  harvest 

nptions,  road  desiqn,  environmental  mitigation  or  fish  and  wildlife 
niques.   Rather,  we  must  examine  such  documents  from  the 
vantage  point  of  outputs  and  how  well  they  meet  our  criteria  for 

rtunity,  water  quality,  wildlife  populations,  complj 
with  :  )'•--,  and  economic  stability  in  terms  of  jobs  and  public 


We  had  ■  the  timber  industry  would  be  pushing  for  a  full, 

inagement  option  such  as  described  by  Alternative 
what  surprised  when  the  industry  asked  that  SORA 
considei  joining  wi  istry  in  supporting  Alternative  2.   We 

ort  because  the  EIS  does 
he  probata  Lity  of 
alternative.  Uscussion  and  review,  the 

i  SORA  was  unanomously  adopted: 

i:R  OF  SORA  URGES  THAT  THE  BLM  ADOPT  ALTERNATIVE  2 
AS  THE  PROPOSED  ACTION  IN  THE  I  MENTATION 

AS  TH  DED  THE  FINAL  EIS  DEMONSTRATES  THAT  SORA'S 

OBJECTIVES  IN  THE  AREA.  TY,  RECREATIONAL 

ROWTH  AND  ECON  "  CNDEED  MET  BY 

" 


11  —  3  I  The  public  should  be  given  the  opportunity  to  comment  on  specific  areas. 

We  are  concerned  that  some  areas,  such  as  Slide  Over,  may  be  more  political 
in  nature  than  based  on  demonstrated  need,  or  the  area's  attributes,  when 
compared  to  other  potential  areas  in  the  state. 

RIPARIAN  AREAS  AND  WATER  OJJALITY-It  would  appear  that  with  the  allocation 
of  over  18,000  acres  of  streamside  units,  that  water  and  fisheries'  values 

I  are  well  provided  for  in  Alternative  2.   In  addition,  the  EIS  should  analyze 
how  these  areas  can  best  be  managed  to  provide  for  old  growth  and  other 
wildlife  needs. 

WILDLIFE-We  recognize  that  as  the  composition  of  the  forest  changes  from 
predominately  old  growth  to  a  managed  forest,  there  will  be  changes  in  the 
wildlife  populations.   However,  there  will  still  be  an  abundant  population 
of  wildlife  for  the  public  to  enjoy.   This  concept  has  not  been  adequately 
discussed  or  described  in  the  EIS.   Considering  the  O&C 

lands,  we  do  not  think  it  necessary  that  every  species  now 
land  must  always  be  found  on  BLM  lands  so  loi  Sone- 

where  in  the  region.   With  the  Riparian  zone  .  i  LI  not 

be  managed  intensivly  for  timber,  this  is  not  a  serious  concern. 


11-5| 


Ilt  was  pointed  out  in  an  earlier  planning  document 
decades  before  any  wildlife  population  will  be  sigr 
think  this  concept  should  be  carried  forward  into  t 


.11  be  several 
icantly  impacted.  We 
final  EIS. 


Following  are  in  areas  of  concern  to  SORA  along 

In  the  analysis  in  the  final  EIS. 


ith 


NORTH  UMPQUA  RIVER-Qur  organization  is  particularly  concerned  that  your 
management  of  the  ri  Lc  beauty  of  the  area,  as 

reased  recreational  pressure  on  the 
area.   Because  it  i:  ltive  area,  it  deserves  specific  discussion 

for  increased  day  and  overnight  use 
Increased  river  crossings  for  foot  traffic,  and  increased 
'he   once  proposed  Bob  Butte  road.   We  would 
' mprovement  oi 

RECREATT  naximum  recreational 

opporti  ment.   This  should  include 

:i  iged  forest, 
tyout,  as  well  as 

■ 

I\REAS  OF  CRITICAL  ENVIRONMENTAL  CONCERN  AND  RESEARCH-NATURAL  AREAS- I t 
appears  that  the  ACEC's  desicions  will  be  made  as  part  of  this  planning 
,  yet  the  EIS  fails  to  give  specific  descriptions  of  the  areas  that 
ild  be  included,  why  they  are  included,  or  how  they  would  be  managed. 


11-7 


11-8 


11-9| 


OLD  GROWTH  AND  THE  SPOTTED  OWL-SORA  appreciates  the  values  of  old  growth 
and  the  apparent  uniqueness  of  the  spotted  owl.   It  has  also  become  abundantly 
clear  in  recent  months  that  a  great  deal  of  study  and  research  is  needed  on 
the  subject,   while  the  EIS  indicates  the  spotted  owl  will  be  gone  from  the 
district  in  a  hundred  years,  the  arguments  are  not  at  all  convincing.  We 
think  that  opportunities  to  manage  for  the  owl  without  the  large  habitat 
allocation  must  be  examined.   Clearly  on  this  district  time  is  not  a 
critical  issue  since  it  will  be  so  long  before  the  major  portion  of  the 
old  growth  is  scheduled  for  harvest. 

Your  EIS  should  show  the  public  how  many  of  the  owls  you  can  protect  for 
the  first  ten  years  as  well  as  for  future  decades  under  each  alternative 
by  carefully  scheduling  your  timber  sales.  It  would  appear  that  we  have 
several  decades  in  which  to  determine  a  proper  old  growth  policy  on  the 
district.  In  the  meantime,  the  Forest  Service  will  develop  its  local 
plans  and  the  researchers  can  provide  the  answers  to  the  many  questions. 
The  EIS  should  deal  with  total  old  growth  on  the  district,  not  just  the 
commercial  forest  lands. 

TIMBER  SUPPLY  AND  LOCAL  ECONOMIC  STABILITY-It  is  clear  at  this  point  that 
some  significant  increases  in  the  even  flow  sustained  yield  are  possible 
from  the  Roseburg  BLM.   For  this  we  are  thankful,  as  our  industry  will  need 
the  timber  and  our  community  will  need  the  jobs  once  the  current  national 
economic  climate  improves.   It  is  our  understanding  from  the  EIS  that 
actual  harvest  levels  will  fluctuate  depending  upon  the  funding  levels 
approved  by  Congress  and  the  price  of  timber.   It  also  appears  that  in  order 


100 


to  reach  the  level  of  harvest  'ou  will  need  big  increases 

in  funding.   We  find  this  very  unlikely  in  the  next  few  years.   While  we 
support  youi  ry,  we  are  concerned  that  the 

I  prop'  ii  Therefore,  we  would  ask  that  the 

i  IS  display  the  harvest  level  for  each  Levels 

of  funding  (current,  10*  higher  or  lower,  15*  higher  or  lower,  etc.). 


11-11 


As  you  know,    a   timber  shortage   is  predicted   for  this   region   in  the  next 
thirty  years  or    so.      While   you  discuss    the   Forestry  Plan    for  Oregon, 
feel    a   more   detailed  discussion  of  BLM  opportunities    to  help  protect 
shortage    should  be  discussed   in   your    final   EIS. 

CONCLUSION- Based  on   the    information  available,    SORA  is  pleased   to  support 
Alternative    2.      It  will  provide    for  affordable    increases    in  harvest  which 
will   provide  a   favorable  climate    for   increased  employment  and  economic 
recovery  while  protecting   the  environment  and  preserving  the  quality  of 
m  Douglas  County.      Options   for   future  old  growth  allocations  will 
remain   in  place  until    future  plans   are  developed  and  better  knowledge 
ll;    available   upon  which   to  make    rational   decisions.      We   urge   that   you  use 
Alternative   2  as   the  proposed  action  in  the   final  EIS  so  that  we  may  more 
fully  analyze   its  effects   in  the  decision  process. 

On  behalf  of  the  Board  of  Directors, 


Georgia  H.   Stiles 
President 


cc     Bill   Leavell,   State  Director 
Bob   Bur ford.    Director  BLM 
SORA  Board  of  Directors 


Response  to  comments  in  L/?tt<-r  11. 

11-1         The  North  Umpqua  River  is  discussed  on  pages  48,   S3,   and  84  ol 
DEIS.  Specific  development  opportunities  will   hr-  addrr-:, 
subsequent  detailed  management  plans  and  environmental   assessments. 

11-2         Recreation  facilities  and  opportunities  are  described  on  pages  47-50, 
80-85  and  126  of  the  DEIS.  Additional  details  are  available  at  the 
Roseburg  District  Office. 

11-3         USDI,  BLM  1980a  {see  References  Cited)  contains  general   policy  and 
guidelines  for  ACECs.   Further  information,    including  the  proposed 
Management  Framework  Plan  (MFP),   an  ACEC  identification  summary  and 
ACEC  plan  element,    is  available  in  the  Roseburg  District  Office.  The 
identification  summary  documents  the  criteria  evaluation,  staff 
analysis  and  public  participation  for  nominated  and  proposed  ACECs. 
The  ACEC  plan  element  provides  a  specific  description,  management 
objectives  and  special  management  requirements  for  all  proposed 
ACECs.  Details  were  published  in  Roseburg  District  Planning 
Newsletters  9,  10,  11  and  in  Brochures  on  Draft  and  Preferred  Land 
Use  Alternatives.  The  public  was  given  opportunity  to  nominate  areas 
and  comment  on  potential  areas  through  the  response  to  land  use 
alternatives  from  the  above  listed  brochures.  Following  designation, 
activity  plans  are  prepared  to  translate  management  requirements  into 
on-the-ground   implementation  actions. 


11-4         All  EIS  alternatives,  except  Alternative  1,  provide  an  allocation  for 
riparian  habitat.  Although  this  habitat  meets  many  wildlife  needs, 
Lang  (1980)  states  that  narrow  riparian  strips  containing  old  growth 
trees  do  not  constitute  old  growth  ecosystems  because  of  the  lack  of 
an  old  growth  microclimate.  As  a  result,  opportunities  to  provide  the 
needs  of  old  growth  dependent  wildlife  species  through  riparian 
habitats  are  quite  limited. 


11-9        The  DEIS  analysis,   including  Table  3-9  and  Appendices  E  and  F, 

addresses  all  old  growth  within  and  outside  the  commercial   forest 
land  base.  Withdrawn  areas  and  non-intensive  commercial    forest  land 
have  been  used  to  satisfy  a  variety  of  resource  uses,   including  eagle 
habitat,  riparian  areas,  owl  habitat,  scenic  values,  etc. 

11-10       See  response  to  common  issue  2. 


11-5         Refer  to  DEIS,  Chapter  3,   Impacts  on  Animals  section,  pages  72-77. 
Also,  see  response  to  common  issue  1. 


11-11       See  response  to  comment  4-1. 


11-6         See  response  to  common  issue  1. 

11-7         The  EIS  analysis  focused  on  short-  and  long-term  impacts  to  the 
spotted  owl   based  upon  current   information.  Refer  to  Chapter  3, 
Impacts  on  Animals,  Threatened  and  Endangered  Animals  and  Conclusions 
'   sections.  Also,  see  response  to  comment  83-6. 


For  the  first  ten  years,   under  original  Task  Force  guidelines,   at 
least  25  pairs  of  owls  would  be  expected  to  remain  under  the 
Preferred  Alternative  (Alt.  9)   as  a  result  of  land  use  allocations 
and  harvest  scheduling.  To  assess  the  effect  of  timber  harvest 
actions  on  spotted  owl  populations  at  the  end  of  each  decade  for  each 
alternative,   it  would  be  necessary  to  have  detailed  long-term  timber 
sale  plans.  Since  this  has  not  been  done,  the  issue  cannot  be 
adequately  assessed.  Refer  to  Chapter  1,  Table  1-5  and  Chapter  3, 
Impacts  on  Animals,  Conclusions  section. 


12 


regon  Wilderness  Coalition 


Main  Office    271  Wesl  12th  Avenue    Eugene  Oregon  97401  [503    J44-0675 
Mi  tro  i  »ffice   IX-kum  Building,  519  SW  ,»rd  Avenue,  Suite  706,  Portland 

Oregon  97204  (5031  224-0201 
Eastern  Oregon  Field  Office    Box  9    Prairii  Cit)    Oregon  97869    S03   820-3714 


101 


Response  to  comments  in  Letter  12  . 


12-1         Under  Council  on  Environmental  Quality  regulations  (40  CFR 

1502.14(a)),  an  EIS  must  consider  a  range  of  reasonable  alternatives. 
Many  reasonable  alternatives  may  be  inconsistent  with  current  agency 
policy.  The  possibility  always  exists  that  the  EIS  analysis  can  lead 
to  revision  or  policy. 


12-1 


We  are  not  so  poor  we  musx  destroy  oui  wilderness,  nor  so  rich  we  can  afford  to     — newton  urury 


15 


15-1 


15-2 


Umpqua  Valley  Audubon  Society 

P.O.   Box  381,  Roseburg,  OR  97470 

August    18,    1982 


lr.  James  Hart,  District  Manager 
Bureau  of  Land  Management 
777  N.W,  harden  Valley  Blvd. 
Roseburg,  Oregon  97470 


Dear  Mi 


Enclosed  are  our  omaniza 
Manaaement  Environmental 


tion  s  comment 
Impact  Stateme 


nt  the  comment 
ard  of  directo 
nto  the  draft 

was  done  deta 
d  result  from 
o  thank  some  < 
nswering  quest 
Dick  Norland  . 

to  meet  with 


s  on  the  Roseburg  Timber 
nt  issued  in  June  of  19  82 . 
iade  in  the  15-page 
We  were  impressed 
statement  and  felt  that 
iling  many  of  the  environ- 
the  various  alternatives. 
f  your  staff  for  the  time 
ions  that  I  had  about  the 
nd  Dave  Palmer  all  took 
me  and  I  certainly  aporeci- 


This  letter  will  supoleme 
document  signed  by  our  bo 
with  the  work  that  went  i 
a  relatively  thorough  job 
mental  impacts  which  woul 
I  would  especially  like 
that  they  spent  with  me 
statement.   Bob  Albei 

from  their  schedules 
ated  i t  . 

Soc  io-economic  Impacts 

The  analysis  of  the  economic  impacts  of  the  various  alternatives  is 

This  part  of  the  impact  statement  is  critical  because 
ill  o^  the  dearadinq  of  the  environment  that  occurs  in  alternatives 
1  throuqh  5  is  beina  done  basically  in  the  name  of  economics  and 
community  stability.   An  adequate  decision  cannot  be  made  unless  the 
economic  analysis  is  adequate. 

1)  The  statement  determines  the  existing  situation  to  be  187.5 
MM  bd.  Ft.   This  average  is  obtained  by  considering  the  years  1976 
through  1980.   The  analysis  should  include  the  last  10  years  rather 
than  t  Lve.   In  addition  it  should  include  the  figures  for 

■ear  1981. 

2)  The  averaqe  12-month  harvest  should  be  determined  using  a 
number  of  different  years.   If  the  existing  situation  were  based  on 
the  averaqe  harvest  for  the  last  three  years,  i.e.  1979,  1980  and 
1981,  isults  would  occur.   For  example,  the 

h  harvest  for  1979,  1980  and  1981  is  159  MM  bd.  Ft. 
this  figure  as  the  existing  situation,  all  of  the  alternatives 


15-2 


15-3 


15-4 


15-5 


15-6 


15-7 


Mr.  James  Hart 
August  18,  1982 
Page  2 

except  for  alternative  8  would  result  in  an  increase  in  timber 
harvesting  and  alternative  6  would  increas  e  the  number  of  jobs 
in  the  local  economy  by  approximately  400. 

3)  On  cage  87  it  is  stated  that  the  economic  projections 
assume  that  under  each  alternative  the  timber  is  promptly  harvested 
and  processed.   The  statement  should  include  information  on  the 
current  situation.   For  example,  if  there  is  a  backlog  of  timber 
that  has  been  sold  but  not  harvested,  that  information  should  be 
available  to  the  public  and  the  decision  maker. 

4)  The  statement  should  analyze  whether  the  timber  market 
can  support  the  increased  harvesting  that  is  projected  by  some  of 
the  alternatives.   It  should  analyze  the  impact  that  a  rapid 
conversion  of  public  old  growth  timber  will  have  on  the  timber 
market.   It  should  attempt  to  analyze  whether  a  reserve  of  old 
growth  timber  will  have  a  stabilizing  influence  on  timber  prices 
and  whether  a  rapid  conversion  of  old  growth  timber  would  result 
in  a  substantial  increase  in  the  value  of  privately  owned  timber. 

5}   Because  one  of  the  main  objectives  of  the  O  &  C  lands  is 
to  stabilize  local  economies,  the  statement  should  analyze  the 
apparent  trend  towards  diversification  that  is  occur ing  in  Douglas 
County.   It  apoears  to  be  the  goal  of  most  Dolicy  makers  in 
Douglas  County  to  diversify  the  economy  so  that  the  swings  in  the 
housing  market  caused  by  national  recessions  will  not  result  in 
such  dramatic  increases  in  unemployment  in  Douglas  County .   I f 
some  of  the  alternatives  would  result  in  the  forest  industry  in- 
creasing its  Drecentage  of  the  market  place  in  Douglas  County,  a 
federal  bureau  could  actually  be  working  against  local  economical 
stability. 

Water  Quality 

1)  There  aopears  to  be  no  statement  of  the  actual  State  and 
Federal  quality  standards  which  must  be  met  in  the  sustained  yield 
unit.   This  information  should  be  included  in  the  statement. 

2)  On  page  68  it  is  concluded  that  substantial  increases  in 
nutrient  concentrations  following  forest  fertilizations  are  not 
expected.   No  sources  are  given  for  that  conclusion.   It  certainly 
seems  that  with  the  amount  of  research  that  has  been  done  in 
agricultural  fertilization,  there  must  be  some  research  available 
to  indicate  whether  stream  concentrations  will  increase  or  stay 
the  same  following  fertilization. 


Soils 


15-8 


1)   We  don't  understand  why  the  withdrawals  for  fragile  sites 
is  so  much  smaller  than  the  inventoried  fragile  soils.   Table  C-2 


15-8 


15-9 


15-10 


102 

Mr.  James  Hart 
August  18,  1982 

|  on  page  125  would  withdraw  approxi- 
mately 2600  acres  for  fragile  sites.   Table  2-14  on  page  34  seems 

Mcate  that  there  are  approximately  9,000  acres  of  fr 
soils. 

2)   The  analysis  of  the  impact  of  the  loss  of  soil  due  to 
intensive  timber  management  is  inadequate.   The  statement  should 

irnount  of  top  soil  that  is  being  lost  from  the 
forest  under  each  alternative,  the  amount  of  top  soil  that  would 
be  added  to  the  forest  under  each  alternative  and  it  should  project 
whether  those  top  soil  losses  can  go  on  indefinitely  without  affect- 
ing the  long-term  productivity  of  the  sustained  yield  unit. 

Vegetation 

1)  The  statement  should  indicate  the  impact  that  the  various 
alternatives  will  have  on  the  present  species  composition  of  the 
sustained  yield  unit.   I  nresume  that  in  many  places  in  the  forest 
mixed  stands  will  be  reDlaced  by  single  species  and  the  states- 

I  should  analyze  whether  this  will  vary  under  different  alternatives. 

2)  If  the  change  in  species  composition  results  in  conversion 
of  a  mixed  forest  to  a  monoculture,  the  statement  should  analyze 
the  environmental  impacts  of  that  change. 

Miscellaneous 

1)   Some  of  the  Roseburg  district  lands  are  public  domain  lands 
which  apparently  should  be  managed  under  The  Federal  Land  Policy 
and  Management  Act  of  1976.   These  lands  should  be  clearly  identified 
in  the  statement  and  the  alternatives  should  assess  the  impact  that 
different  legal  restraints  will  have  on  that  land. 

12)   It  appears  that  some  of  the  alternatives  may  violate  State 
and  Federal  water  quality  standards.   If  they  do,  we  believe  it  is 
inappropriate  for  these  alternatives  to  be  considered  because  they 
are  not  alternatives  that  could  be  implemented. 

13)   The  statement  should  indicate  the  amount  of  merchantable 
timber  that  is  being  added  to  the  sustained  yield  unit  annually  at 
the  present  time. 

4)   The  statement  should  indicate  what  portion  of  the  projected 
harvest  under  the  preferred  alternative  is  due  to  projections  for 
15-14  genetically  improved  trees,  what  portion  is  due  to  precommercial 
thinning  and  commercial  thinning,  and  what  portion  is  due  to 
fertilization. 


15-11 


15-15 


Mr.  James  Hart 
August  18,  1982 
Page  4 

I  to  assess  the  environmental  impacts  of  their  activities  on  ' 
and  wet  lands.  ,t   able  to 

concerning  the  identification  of  those  lands  or  any  asses- 
I  of  the  impact  of  the  alternatives  on  those  lands. 

At  this  time  we  do  not  expect  to  be  submitting  any  oral  stu' 
at  the  public  meeting. 

Sincerely, 


James  A.  Arneson 

Conservation  Committee  Chairman 


15-151 


5)      Executive  Order    11990    and    11880   directs    Federal    agencies 


Response  to  ccmnients  in  Letter  15. 

15-1         The  average  12-month  sales  frcm  the  Roseburg  District   frcm  1972 
15-2         through  1981  was  200.2  MM  bd.   ft.  The  average  12-month  harvest  from 
the  Roseburg  District  frcm  1972  through  1981  was  194.9  MM  bd.   ft. 
Fluctuations  of  over  25  percent  above  or  below  the  allowable  cut  are 
not  uncanmon  in  tracing  the  annual  harvest  through  the  past  decade. 

15-3         Timber  sold  but  unharvested   in  the  Roseburg  District,   as  of  March  31, 
1983,  was  616.9  MM  bd.   ft. 


total  employment  provided  by  the  wood  products  sector  by  less  than  1 
percent     For  example     Table  2-17  reports  lumber  and  wood  products 
employment  in  Douglas  County  (1977-1980  avg.)  of  8.500  and  total 
employment  of  35,000     Under  the  no  action  baseline  (Table  3-18), 
Alternative  1  could  add  537  jobs  in  the  timber  industry  with  total 
employment  increasing  by  1,135.  During  1977  through  1980     timber 
industry  jobs  represented  24.3  percent  of  total  employment  in  Douglas 
County.  Under  Alternative  1     timber  industry  jobs  would  represent 
25.0  percent  of  total  employment  in  the  county. 


15-4         A  number  of  studies  which  include  estimates  of  the  price-quantity 
relationship  for  lumber  and  wood  products  at  the  national   level  or 
the  derived  price-quantity  relationship  for  stumpage  from  public 
ownerships  in  the  Pacific  Northwest  are  available  (Haynes  1977;  Adams 
et  al.  1977;  Adams  1977;  Haynes  and  Adams  1979;   Youngday  and  Fight 
1979;  Adams  and  Haynes  1980;    and  Haynes  et  al .  1981).  All  of  these 
studies  suggest  that  changes  in  supply  of  timber  of  the  magnitude  of 
the  alternatives  in  the  DEIS  will  have  no  effect  on  the  market 
clearing  prices  of  stumpage  or  manufactured  wood  products. 

15-5         Pages  54-55  and  Tables  2-17  and  2-18  of  the  DEIS  discuss  and  display 
recent  trends  in  economic  diversification  within  Douglas  County. 
Because  timber  industry  jobs  support  jobs  in  other  sectors  (service, 
retail   trade,  non-wood  manufacturing,  etc.),   an  increase  in  the 
number  of  timber  dependent  jobs  would  increase  the  percentage  of 


15-6         The  State  of  Oregon  has  determined  that  the  requirements  of  the 

Forest  Practices  Act  meet  the  objectives  of  State  and  Federal  water 
quality  standards.  (Refer  to  ORS  340;  copies  are  available  at  Oregon 
Dept.  of  Environmental  Quality  and  BLM  offices.) 

15-7         The  text  has  been  revised  in  the  FEIS,  Chapter  3,   Impacts  on  Water 
Resources,  Water  Quality  section. 

15-8         The  withdrawals  for  fragile  sites  are  part  of  the  TPCC  inventory  and 
do  not  coincide  with  the  soil  inventory  which  included  fragile  soil 
areas  (see  DEIS,  Appendix  C,  page  123). 

15-9         There  is  no  known  research  which  quantifies  loss  of  forest  productiv- 
ity resulting  frcm  incremental  losses  of  topsoil. 


16 


15-10      Ihe  vegetative  composition  which  currently  exists  in  the  SYUs  is 

described  in  Chapter  2,  Vegetation  section.  On  page  70  of  the  DEIS, 
it  has  been  noted  that  vegetation  oanposition  in  the  SYUs  would 
change  according  to  the  level  of  harvest  under  each  alternative  (see 
Table  3-8  and  Appendices  E  and  F).  Species  composition  is  not 
expected  to  change,  as  indicated  on  page  71  of  the  DEIS. 

15-11       The  issue  of  separate  management  was  not  identified  in  scoping. 
Therefore,   it  was  not  analyzed   in  the  EIS.  Also,  see  response  to 
comment  7-1. 

15-12      See  response  to  comment  15-6. 

15-13       The  average  annual  growth  presently  being  added  to  the  intensive  base 
for  Alternative  9  is  5,165  MCF  or  31.1  MM  bd.   ft.  and  to  the 
intensive  and  constrained  base  for  Alternative  4  is  5,424  MCF  or  32.7 
MM  bd.    ft. 

15-14       See  response  to  common  issue  3. 

15-15       Impacts  are  expected  to  be  insignificant  to  wetlands  and  aquatic 

vegetation  for  all   alternatives  except  Alternative  1.  Refer  to  DEIS, 
Chapter  3,  Impacts  on  Vegetation,  page  69  and  to  Appendix  C,  Table 
C-4. 


103 


Umpqua  Valley  Audubon  Society 

P.O.   Box  381.  Roseburg,  OR  97470 


August  18,  1982 

Mr.  James  Hart,  District  Manager 
bureau  of  Land  Management 
777  N.W.  Garden  Valley  Blvd. 
Hoseburg,  Oregon  97^70 

Dear  Mr.  Hart, 

The  following  Is  our  comment  on  the  June  1982  Lraft  Hoseburg 
limber  Management  Environmental  Impact  statement. 

The  limber  Management  ols  Is  Inadequate  In  giving  a  balanced 
range  of  alternatives.   Alternatives  1  through  7  proposes  to  harvest 
between  289  to  176  MMBF  per  year  vs.  Alternative  B'r  Alter- 

natives 1  thru  5  are  totally  unacceptable  from  an  ecological  stan-1 
point  to  maintain  forest  diversity.   While  the  prescriptions  proposed 
In  Alternatives  6  and  7  are  not  quite  as  far  out  of  line,  wildlife 
and  watersheds  would  only  fair  slightly  better.   Our  claim  Is  evi- 
denced from  statements  in  the  Dr.13  such  as: 

(a)  Cavity  nesters  are  predicted  to  "fall  below  self-sustaining 
levels"  In  all  but  alternatives  6,  7  and  8  and  "snag  dependent  wild- 
life would  be  greatly  reduced  In  the  long  term"; 

(b)  "Planned  timber  harvest  would  so  alter  cover  composition  that 
elk  populations  are  expected  to  decline  over  time  in  all  alternatives 
except  8."   And,  "there  are  no  long  term  provisions  for  retain! 
mature  or  old  growth  forest  beyond  the  fourth  decade  for  survival 
cover  In  this  Important  area  and  this  absence  could  cause  population 
declines  to  proceed  faster  If  severe  weather  occure 

(c)  Alternative  6,  and  not  the  preferred  alternative,  Is  the  only 
option  outside  of  Alternative  8,  that  would  provide  habitat  for  25 

or  more  pairs  of  spotted  owls  as  recommended  by  the  Oregon  endangered" 
Species  lask  Force  under  the  previous  300  acre  prescription.   And 
only  Alternative  8  would  provide  a  genetically  viable  pooulatlon 
under  the  more  recently  suggested  1000  acre  prescrlotlon. 

We  feel  that  Alternative  7.  the  tfo  Herbicide,  .io   fertilizer  Alter- 
native, serves  to  further  accentuate  BLK's  bias  that  forestry  with- 
out herbicides  doesn't  work,  rather  than  trying  to  look  for  methods 
that  would  generate  some  additional  employment  and  would  provide  us 
with  a  healthy,  poison  free  environment. 


-3- 


16-1 


16-2 


The  Ho   Herbicide  Alternative  does  not  sufficiently  address  the 
specific  assumptions  that  allows  the  BLM  to  take  allowable  cut 
credit  for  the  use  of  herbicides,   Manual  release  methods  are 
not  fully  discussed  for  which  allowable  cut  credit  should  also 
be  received. 

We  feel  strongly  that  Alternatives  1  through  7  provide  a  skewed 
range  of  alternatives,  shifted  heavily  to  the  side  of  maximum 
commodity  production.  Yet   BLM  seemingly  expects  Alternative  8 
to  provide  a  balanced  "extreme"  to  Alternative  1.   Alternative 
1  proposes  to  harvest  289  MMBF  per  year.  The  September  1981  Pre- 
ferred Land  Use  Alternative  document  maintains  that  the  district 
only  has  the  potential  to  produce  2?6  MMBF  per  year.   Similarly 
the  DEIS  preferred  alternative's  annual  cut  of  2^9  KKBF  has  been 
Increased  from  September  1981  preferred  alternative's  recommended 
harvest  of  232  MKBF.   Are  these  both  suppose  to  be  the  same  pre- 
ferred alternative?  Again,  the  cut  has  been  skewed  to  one  direction 
with  both  Alternatives  1  and  2  proposing  harvest  in  excess  of  the 
prescoplng  meeting's  maximum  timber  harvest,  Alternative  A,  which 
proposed  266  KKBF.   While  the  preferred  alternative  was  Increased 
by  i4  MMBF  and  the  maximum  timber  harvest  alternative  Increased 
by  23  MMBF,  Alternative  7  Is  only  3  MMBF  below  the  former  Alter- 
native C,  and  Alternative  8  Is  only  5  MMBF  below  what  was  formerly 
called  D. 

We  realize  that  the  various  alternatives  are  for  purposes  of  dis- 
cussion and  the  number  of  assorted  "timber  first"  proposals  doesn't 
necessarily  insure  that  Alternative  8  will  not  be  fairly  evaulated. 
However,  if  a  "travel  agent"  were  to  open  his  briefcase  and  present 
you  with  seven  enticing  vacation  packages,  all  In  seven  states 
east  of  the  Mississippi  River,  but  also  happened  to  have  a  trip  to 
Colorado — although  you  may  leaf  through  all  the  pages  of  the  travel 
brochures,  no  one  really  expects  that  the  odds  are  you  are  going  to 
choose  Colorado.   If  however,  the  travel  agent  wished  to  be  sure 
that  the  western  part  of  the  country  was  equally  well  represented 
in  your  potential  travel  plans,  It  would  behoove  him  to  then  also 
have  a  few  brochures  from  Utah,  Montana  or  Wyoming. 

Similarly,  we  would  like  to  see  a  few  alternatives  In  your  draft 
EIS  package  other  than  really  only  one  that's  on  our  side  of  the 
river.   If,  for  the  analogy.  Alternative  8  Is  to  the  "west"  and 
Alternatives  1.2,3  etc.  are  to  the  "east",  you  have  to  admit  that 
If  Alternatives  6  and  7  are  "west"  at  all,  then  they're  still  drip- 
ping on  the  shore  where  they  Just  barely  got  across  the  rlveri 

Furthermore,  Alternative  8  isn't  nearly  as  far  "west"  as  Alternatives 
1.2, 3, 4,  and  5  are  "east".   If  you  are  going  to  have  5  alternatives 
all  In  excess  of  200  MMBF,  then  you  can  consider  a  few  other  alter- 
natives less  than  100  MMBF.   If  you  wish  to  have  an  alternative, 
such  as  number  1,  which  by  your  own  admission  Is  13  MMBF  above  your 
potential  to  produce,  then  an  analysis  of  the  ecological  Impacts  on 


16-3 


16-4 


16-5 


elk  and  cavity  nesters  by  only  harvesting  50  MiBF,  25  tmaT,    or 
0  KKBF  should  also  be  considered.   Alternative  e  would  basically 
only  allow  one  population  of  elk  (In  the  Tyee  area)  to  hold  Its  own, 
according  to  the  draft  ilS.   Let's  consider  an  alternative  that 
would  maximize  elk,  spotted  owls,  bald  eagles,  cavity  nesters  and 
anadramous  fish  In  all  areas  of  the  forest.   Only  this  type  of 
alternative  would  properly  balance  Alternatives  1  thru  5-   In  other 
words  Its  O.K.  If  your  travel  agent  wants  to  offer  dream  trips  to 
Bangor,  Maine,  but  let's  also  have  a  trip  to  San  Diego,  California. 
Alternative  8  doesn't  get  past  Denver,  Colorado. 

Ihe  "new"  preferred  alternative  Increases  timber  harvesting  by  <*8 
MMBF  over  the  current  annual  allowable  cut  level,  lo  harvest  this 
timber,  four  Intensive  management  practices  are  employed — spacing 
control  In  young  stands,  commercial  thinning,  fertilization,  and 
planting  of  genetically  Improved  trees.  To  Insure  that  future 
timber  management  policies  and  practices  do  In  fact  "contribute 
to  the  economic  stability  of  local  communities"  as  set  forth  In  the 
O&C  Act,  we  ask  that  the  F£IS  fully  analyze,  and  present  documented 
evidence  that  will  demonstrate  the  feasablllty,  and  explain 
degree  of  probability  of  success,  before  Intensive  ia.iaieie.it  3.etno-s 
las  described  are  employed  any  more  extensively. 

Given  a  favorable  market,  It  Is  obvious  that  accelerated  t: 
harvest  can  produce  a  local  economic  "boom".   We  wish  tne  .-'Eli  to 
offer  firm  evidence  that  such  accelerated  harvest  as  proposed  In 
the  preferred  alternative,  will  not  eventually  result  in  economic 
"bust".   Our  concern  Is,  that  In  meeting  the  Immediate  timber  demands 
of  this  decade  that  both  our  economic  and  natural  environments  are 
not  "short  changed"  In  future  decades. 

In  a  public  appearance  last  year,  U.S.  Forest  Service  Regional 
Forester,  Richard  Worthlngton  remarked  that  certain  Scandinavian 
countries  are  facing  severe  timber  shortages  due  to  major  miscal- 
culations In  their  allowable  cuts.   Our  total  future  timber  supplies 
should  not  be  predicated  on  the  assumed  accuracy  of  allowable  cut 
calculations  and  high  risk  Intensive  management  techniques.  If  the 
failure  of  any  one  of  these  techniques  could  leave  us  with  an  economy 
below  our  minimal  level  of  "stability". 

Conservative,  yet  sound  economic  advise,  Is  to  never  Invest  more 
than  you  can  afford  to  loose.   High  risk  Investments  often  offer 
the  potential  of  paying  the  greatest  dividends.   But  If  an  Investor's 
"sure  thing"  stocks  should  go  "belly-up"  due  to  unforseen  complica- 
tions, then  having  a  remaining  nest  egg  safely  tucked  away  In  some 
low  Interest  paying  bank  or  S4L  provides  a  basic  level  of  security. 

Our  old  growth  forests  are  such  a  nest  egg.   It  Is  no  wiser  to 
gamble  on  our  future  by  liquidating  vast  quantles  of  old  growth 
In  the  next  decade  for  the  hoped  for  benefits  of  Intense  "forest" 
management,  than  It  would  have  been  for  the  Investor  to  have  liquid- 
ated his  entire  S&L  account  to  assume  the  same  high  Intensive  money 
management  risks. 


104 


16-6 


16-7 


16-8 


2. 

16-9 


So  before  we.  the  members  of  the  public,  Invest  anymore  of  our 
old  growth  nest  egg  In  your  Intensive  management  forest  Invest- 
ment scheme,  we  would  like  you  to  more  fully  address  some  of  the 
basic  forest  Investment  questions  not  yet  fully  dealt  with  In  the 
draft  KIS -   This  way  you  can  better  demonstrate  to  us,  your  In- 
vestors, that  you  are  really  wise  managers  and  that  you 
have  accurately  accessed  both  the  environmental  and  economic  risk 
you  may  be  asking  us  to  assume. 

The  EIS  deals  very  little  with  the  specific  Issue  of  timber  man- 
agement despite  Its  title  a         nber  Management" 
EIS  should  address  the  ecological  and  financial  feasibility  of  the 
various  Intensive  management  techniques  as  recommended  In  the  pre- 
ferred alternative  and  discuss  the  scientific  basis  by  which  these 
methods  would  be  applied. 

The  EIS  does  state  that  compaction  from  "dragging  logs  and  operat- 
ing ground-based  logging  equipment",  "can  reduce  the  vegetative 
productivity  of  the  soils  by  10  to  25  percent"  and  "compaction  and 
reduced  Infiltration  capacity  have  been  found  to  last  at  least  55 
years  (tower  197*0  and  therefore  may  last  longer  than  harvest  rot- 
ation periods."   Also  a  general  prescription  Is  given  for  high  lead 
I  cable  yarding  vs.  tractor  skidding  etc.   Yet  the  ills  seemingly  re- 
fuses to  question  or  examine  the  Justifications  for  the  present 
methods  of  clear  cut  timber  harvest  and  the  associated  machinery. 

It  Is  as  though  the  public  Is  to  unquestionably  accept  that  the 
BLK  applied  methods  and  practices  are  always  best,  and  the  agency 
should  only  have  to  deal  with  the  Issue  of  how  much  timber  harvest. 
Instead  of  the  additional  Issue  of  the  ways  In  which  It  Is  accomp- 
lished. 

Different  alternatives  of  timber  harvest  methods  should  also  be 
explored  to  evaluate  the  possibilities  for  reduced  soil  erosion 

I  and  compaction.   How  would  greater  numbers  of  shelterwood  prescrip- 
tions reduce  the  need  for  shade  cards,  brush  release,  "post-treat- 
ment surveys"  etc.? 


The  Dais  doesn't  address  these 
told  that  "an  environmental  ass 
dress  the  effect  of  the  harvest 
this  way  the  BLM  avoids  having 
ltlmate  scrutiny.   As  these  are 
also  have  a  say  to  the  methods 
them.   What  may  be  the  most  cos 
be  neither  the  most  cost  or  eco 
by  only  dealing  with  these  ques 
major  policy  decisions  are  not 
ysls  or  review. 


sorts  of  questions.   Bather  we  are 
essment  of  a  timber  sale  will  ad- 
method,  yarding  system"  etc.   In 
their  preferred  methods  face  leg- 
public  forest,  the  public  should 
that  are  employed  In  harvesting 
t  efficient  In  the  short  run,  may 
logically  efficient  In  the  long  run. 
tlons  on  the  basis  of  Individual  E.A. 
available  for  concerned  public  anal- 


Page  68  of  the  DEIS  states  that  "the  chemical  quality  of  surface 
water  would  be  affected  by  slash  disposal."   And  "that  only  Alter- 
native 8  would  provide  adequate  protection  for  streams."  Ihe  EIS 


I  should  further  discuss  the  Impacts  to  the  biological  systems  of 
first  and  second  order  streams  of  Introducing  "fnstream  concen- 
trations of  ammonla-nltro«en  and  manganese"  that  "could  exceed 
recommended  water  quality  stnndards." 

3.  The  DEIS  states,  buffers  "are  expected  to  minimize  herbicide 
drift  or  accidental  direct  spraying  of  water  bodies"  and  move- 
ment of  herbicides  through  soil  is  usually  mi  of 
Inches  or  a  few  feet."   Also,  "some  detectable  amounts  may  reach 
the  streams",  "due  to  pilot  error",  but  "planned  delivery  techni- 
ques would  reduce  or  prevent  spray  from  drifting  Into  i 
The  nature  of  these  statements  acknowledges  that  risks  neverthe- 
less exists,  and  all  one  can  reasonably  expect  to  do  Is  "minimize" 
problems  so  they  "usually"  go  as  they  are  suppose  to.   xTet 
know  that  on  occasion  open  water  bodies  are  sprayed,  or  the  risk 

I  of  herbicides  carried  In  subsurface  water  does  exist.  To  adequately 
assess  the  Impact  of  herbicides,  some  statistical  <>:.  .Id 

be  given  of  percent  error  (avoidable  or  unavoidable)  In  herbicide 
application.   And  what  are  the  Impacts  on  the  biological  systems 
so  affected? 

Also  the  DEIS  mentions  how  "fast-growing  hardwoods,  such  as  red 
alder  or  vine  maple,  overtop  and  suppress  slow-startlnf  conifer 
seedlings".   Yet  there  Is  no  discussion  of  how  broad  leaf  trees 
or  shrubs  might  aid  the  growth  of  conifers  by  providing  shade  on 
southern  exposures.   Also  there  Is  no  Information  on  the  contri- 
butions of  nitrogen-fixation  by  various  species,  although  studies 
have  been  done  in  southern  Oregon  and  quantifiable  data  exists. 

Fage  76  of  the  DEIS  says  "dlesel  oil  Is  sometimes  used  as  a  carrier 
for  forest  herbicides",  "however,  data  are  Insufficient  to  predict 
the  Impacts  of  dlesel  oil  carrier  on  animals  In  the  EIS  area.' 
on  page  87  you  state,  "phenoxy  herbicides  as  applied  do  not  affect 
birds  or  eggs  unless  dlesel  oil  is  used  as  a  carrier."  Based  on 
this  last  statement  It  seems  that  it  would  be  reasonable  for  the 
EIS  to  consider  there  Is  a  potential  for  an  adverse  Impact  on  avian 
life  as  spray  operations  normally  coincide  with  spring  breeding 
bird  activities.   What  levels  of  phonoxy  herbicides  with  dlesel 
produce  adverse  effect  on  birds  and  their  eggs?  How  does  this  com- 
pare with  herbicide  treatments  applied  In  the  field? 

Science  deals  In  probabilities.   While  the  BLK  currently  uses  herb- 
icides approved  by  the  Environmental  Protection  Agency,  based  on  a 
scientific  body  of  evidence  that  maintains  that  herbicide  use  does 
not  present  any  unacceptable  human  health  risk,  there  also  exists 
a  certain  scientific  body  of  evidence  that  phenoxy  residues  do  blo- 
accumulate,  do  move  through  the  soil  via  leaching,  do  cause  mut- 
ations and  cancer  and  are  toxic  In  lower  than  measurable  amount::. 
Therefore,  speaking  scientifically,  we  can  neither  say  that  herb- 
icides are  totally  safe  or  totally  dangerous.   Given  both  confllct- 
lnc  scientific  bodies  of  knowledge,  we  can  only  conclude  that  since 
the  EM  currently  approves  the  use  of  2,4-D  (supposedly  based  on 
scientific  evidence)  as  a  defoliant,  that  there  presently  exist  a 


16-11 


-7- 


16-12 


16-13 


greater  than  50  •'  probability  (to  the  extent  there  Is  more  evidence 
for  than  against)  that  these  herbicides,  from  a  human  health  stand 
point,  are  safe.  The  EIS  should  therefore  address  the  fact  that 
there  Is  a  least  some  lesser  probability  that  herbicides,  as  they 
are  presently  applied,  are  not  safe.   The  FEIS  should  more  fully 
discuss  that  the  level  of  risk  therefore  assumed  unavoidably  by 
certain  members  of  our  population,  may  not  be  an  acceptable  level 
of  risk  to  these  Individuals. 

In  a  report  by  the  Comptroller  General  of  the  United  States:  Better 
Lata  .Jeeded  To  Determine  The  Extent  To  Which  Herbicides  Should  Be 
Used  On  Forest  Lands,  U.S.  General  Accounting  Office  CED-»l-4b, 
April  17.  19B1  It  Is  generally  concluded  that  the  question  of  ex- 
tent of  replacement  of  herbicide  with  non-herblclde  treatments  can- 
not be  settled  largely  because  the  BLK  and  Forest  Service  have  not 
kept  adequate  records  of  cost  or  effectiveness,  or  make  comparlslons 
among  different  sites  to  determine  why  certain  methods  worked  on 
particular  sites.   On  page  51  it  stated,  "The  agencies  do  not  know 
the  total  cost  for  the  various  methods  used  to  carry  out  site 
preparation  and  release  work  and  cannot,  therefore,  reliably  use 
cost  as  the  major  determinant  for  selecting  among  alternative 
methods."   If  this  Is  the  Roseburg  BLK's  problem  the  FEIS  should 
explain  so,  and  offer  ways  to  begin  developing  this  data. 


'*.  The  Bureau  explains  that  200  lbs.  of  fertilizer  per  acre  will  be 
used  In  portions  of  the  forest  with  exception  of  Alternative  7, 
but  little  data  Is  given  to  substantiate  Its  assumed  benefits. 
What  are  the  impacts  of  forest  fertilization?  The  FEIS  should 
16"14  address  problems  associated  with  the: 

|  a.  problems  of  long  term  Impact  to  forest  soils. 
16-15'  D*  consequences  of  the  runoff  of  nitrogen  Into  streams. 
jc.  Impacts  on  delicately  adapted  Improved  trees. 
|d.  lack  of  availability  due  to  worldwide  energy  supplies  which 
could  get  worse. 


16- 16 1 
16^7 


16-18 


What  Is  the  per  cent  growth  gain  per  acre  fertilized  and  by  what 
research  Is  this  substantiated  that  this  technique  will  be  success- 
ful in  Roseburg1 s  drier  climatic  regimes,  particularly  on  south 
facing  exposures?  Most  fertilization  experimentation  has  been  done 
on  soils  known  to  be  low  In  nitrogen.   Because  of  Roseburg* s  low 
rainfall  as  compared  with  the  rest  of  the  Pacific  Worthwest,  why 
shouldn't  we  assume  that  nitrogen  needs  are  less,  as  the  lower 
rainfall  tends  to  minimize  leaching-   In  fact  wouldn't  fertilization 
actually  Increase  the  soil  moisture  stress?  Since  Roseburg  Is  not 
like  northwestern  Oregon,  the  BLK  should  produce  research  on  soils 
substantially  similar  to  those  proposed  for  this  fertilization 
program,  before  substantial  increases  In  the  allowable  cut  are 
made,  if  a  sustained  yield  Is  predicated  on  the  success  of  this 
technique.   It  is  our  understanding  that,  pending  further  research, 
the  Forest  Service  made  a  decision  not  to  take  allowable  cut  credit 
for  fertilization  even  in  northwestern  Oregon. 

Table  3-2  on  page  66  estimates  that  in  the  next  decade  under  the 


16-19 


16-20 


16-21 


preferred  alternative,  there  will  be  an  additional  loss  of  pro- 
ductivity on  7.872  acres  of  BLK  land.   2,6^7  acres  would  loose 
their  productivity  even  under  Alternative  8.   (It  seems  Ironic 
that  these  acres  be  considered  part  of  what  the  BLK  chooses  to 
call  "Sustain  Yield  Units"  (SYU's).)   Ihe  draft  EIS  states  that 
total  loss  of  nitrogen  from  clearcuttlng  and  slash  burning  can 
reach  as  high  as  9".      But  for  comparison  BLK  settled  for  an  ex- 
pected loss  of  b%   nitrogen  and  phosphorus  and  a  JyC   loss  of  Calcium 
and  Potassium.   For  the  four  elements  this  would  result  In  a  total 
loss  of  6,86l  tons  in  the  next  decade  (Table  3-3)-   Would  placing 
5603  tons  of  nitrogen  fertilizer  on  56.029  acres,  at  200  lbs/acre 
(under  Alternative  <*) ,  begin  to  make  up  for  this  soil  loss? 

If  the  allowable  cut  Is  figured  on  the  basis  that  the  combination 
of  two  or  more  Intensive  management  treatments  (I.e.  first  fert- 
ilizer then  thinning)  will  double  the  rate  of  growth,  and  there- 
fore permit  a  larger  annual  cut,  what  documentation  Is  there  that 
this  sort  of  "piggybacking"  will  in  fact  produce  the  anticipated 
extra  Increase  in  growth?  An  analysis  of  any  such  assumptions 
should  be  made  in  the  EIS  If  the  combination  of  two  or 
practices  Is  assumed  to  result  In  any  greater  growth  than  If  only 
one  practice  Is  employed. 

Under  the  preferred  alternative  333,319  acres  will  result  In 
trees  with  a  minimum  harvest  age  (HHA)  of  50  years.  The  FJS 
should  address  If  the  benefits  gained  by  harvesting  trees  at 
this  younger  KHA,  would  outweigh  the  long  term  cost  In  loss  of 
superior  saw  timber  found  In  trees  In  excess  of  lb.lt   Inches  dbh 
were  these  trees  not  harvested  before  they  reached  greater  matur- 
ity.  Also  would  such  a  policy  be  In  compliance  with  the  04C  Act's 
requirement  of  providing  "for  permanent  forest  production"? 

Ihe  EIS  states  that  "target  stocking  levels  of  2^5  to  320  trees/ 
acre  cannot  always  be  achieved  by  the  Initial  planting."  £ven 
with  "post-treatment  surveys",  of  the  Roseburg  District's  391,100 
acres  of  commercial  forest  land,  how  many  acres  are  currently  un- 
stocked  or  under  stocked?  How  will  additional  Intensive  manage- 
ment practices  alleviate  or  contribute  to  this  problem,  If  these 
problems  have  not  met  with  solutions  under  present  practices? 
Have  any  growth  studies  been  conducted  on  Roseburg  zU.   lands  to 
show  that  these  techniques  are  successful  under  your  particular 
set  of  environmental  circumstances? 

In  terms  of  site  preparation,  what  assumptions  are  being  made  that 
a  certain  per  cent  of  natural  seeding  will  serve  to  make  up  for 
stocking  failures?   It  must  be  recognized  In  the  EIS  that  with 
the  proposed  rapid  rates  of  cutting,  that  stands  that  provided 
gratuitous  seed  will  soon  be  gone.   What  assumptions  are  being 
made  as  to  how  many  units  will  require  replanting?   Is  good  site 
preparation  an  assumption  on  which  the  allowable  cut  Is  based?   If 
so,  the  EIS  should  analyze  your  site  preparation  problems. 

-Jg-236-li°  what  extent  Is  the  projected  Increase  In  the  allowable  cut 


16-22 


-9- 


16-23 


16-24 


16-25 


16-26 


16-27 


16 


dependent  upon  the  use  of  Improved  genetic  strains  of  trees? 
The  EIS  should  assess  the  probable  success  that  can  be  expected 
to  be  met  given  the  Inadequacy  of  research  that  has  so  far 
occured  with  their  use.   Also  the  EIS  should  assess  If  this  Is 
really  a  viable  technique  for  Increasing  production  as  the  tree 
Improvement  programs,  as  required  by  Instruction  Memorandum 
0R-79-334.  are  at  this  time  behind  schedule. 

One  Justification  offered  by  the  Dais  for  "the  eventual  planting 
netlcally  Improved  trees  on  90  percent  of  the  Intensive  tlm- 
nductlon  base,"  Is  that  "maintaining  a  broad  selection  of 
parent  trees  would  ensure  variability  In  genetic  populations". 
While  this  might  Insure  "variability"  It  can't  replace  the 
specific  genes  of  those  tree  species  that  were  adapted  to  those 
site  specif iciocatlons.   Also  It  Is  offered  that  "bLi\  administers 
29  percent  of  the  total  forest  land's."   Is  this  meant  to  Infer 
that  the  other  ?1 t   can  be  assumed  to  provide  natural  stock?   It 
should  be  expected  that  adjacent  land  ownerships  will  also  adopt 
similar  Intensive  forestry  practices. 

We  agree  with  the  DiilS  that  until  "the  symbiotic  relationships 
between  plants  and  animals  that  function  In  old  growth  stands" 
are  "fully  understood"  It  Is  Important  to  maintain  "a  representa- 
tive range  of  the  old  growth  forest  and  associated  floral  and 
faunal  genotypes."   We  take  strong  exception  that  "all  alternatives 
except  Alternatives  1,2  and  5  would  provide  adequate  representation 
of  the  original  old  growth  systems."  This  Is  an  Incredible  state- 
ment, when  other  parts  of  the  DEIS  acknowledge  that  most  other  old 
growth  dependent  species  will  be  reduced  below  viable,  self-sus- 
taining levels  except  for  Alternative  8. 

Special  area  designations  such  as  ACEC  s,  RMV's  and  outdoor  ed- 
ucation areas  will  comprise  no  more  than  .7/-'  of  the  forest  under 
any  of  the  alternatives.  The  proposed  old  growth  Bear  Gulch  MA 
recommended  by  the  Federal  Research  Jatural  Area  Committee,  has 
not  only  been  dropped  but  Is  not  even  mentioned  In  the  EIS.   Ihe 
acreage  of  the  proposed  480  acre  Jorth  Kyrtle  RNA  has  been  cut 
In  half.   We  ask  that  this  acerage  be  restored  to  the  full  uncut 
480  acres  as  It  was  previously  represented  by  the  BLr.  and 
recommended  by  Dr.  Jerry  Franklin  and  the  Research  Natural  Area 
Committee. 

We  take  exception  to  the  statement  that  the  preferred  alternative 
Is  consistent  with  Statewide  Planning  Goals  number  4  and  5«   Ihi 
liquidation  of  our  old  growth  as  envisioned  in  the  preferred  alter- 
native would  not  be  "to  protect"  this  "natural  and  scenic  resource". 
Slmilarily  It  would  not  serve  "to  conserve  forest  land  for"  old 
growth  "forest  uses". 

|4.5,t  of  the  Roseburg  BLM  District  Is  in  public  domain  lands  and 
subject  to  different  laws.   Ihe  ownership  is,  in  Itself. 
Justification  for  true  multiple  use  and  wildlife  habitat  retention. 


16-30 


16-31 


105 

Under  the  Endangered  Species  Act  of  1973  It  t  all 

I  departmenl  1  seek  to  conser- 

species  ind  I  -  orltles 

in  furtherance  of  -;s  of  this  Act."   lable  3  of  th 

.-.mary  Broc  ore  can  be 

to  enhance  the  habitat  of 
then  propoj 
land  allocation,  that  would  only  serve  tc  mount 

ting  eagle  habitat, 
your  "authorities  in  furtherance  of  t!  -:t." 

I-rotoctlng  bald 

additional  h  Lded  to  encourage  at  least  s 

reestabllshment  of  pr-vlous  historical  populatlc: 
you  assure, 

inly  small  population.  location  foi 

i.dll  Ulini 

their  obligation 

s  that  construction  of  ne 
to  harassment  of  wildlife  and  r  ge  carnivore 

habitat  witln  one-half  mile  of  these  road 
of  roads  mean  more  access  by  hm 
is  probable."   Also,  "Adverse  Impacts  to  el^  would  occur 

78  you  stated  ,  "1  h 

be  affected  only  to  the-  extent  that  road  construction  cou  1 

previously  unaccesslble  areas.  itlfled 

or  qualified."   If  it  con  be  "qualified"  for  ot 

that  it 

why  should' nt  the  same  i,    and  thus 

and  endangered  species?   Also  th 

within  eagle  nest  sho 

alternatives,  why  is  it  unreason 

more  llkel;  In  the  lone  run  If  an  alternative  ot 

were  selected'' 

Ihe  CEIS  states  that  an  "envlronm 
.  peolflc  action, 
la      Dies  known  to  be  present  on  the  sit 
I  measures  to  be  taken."  Ihls  doe?  not  address  t 
ened  on>'  endangered  species  may  very  well  not  bi 

ivlronmental  analysis"  (i.e.  the  plant  is  not  in  bloom)  an" 
I  therefore  inadvertently  destroy 

In  western  Oregon  about  30  secondary  hole  nestln 
pendent  on  14  primary  excavators  to  provl  ' 

in  which  to  nest  (Ihe  .ieed  For  '..'lldllfe   a-lt-t  llv.  -■  '■ 
On  PL,,  -  ■■.anaged  forest  Lor,'    In  Western  Cre-  — .  •   -    __. 
"to  manage  primary  excavators  at  the  5o   ercent  1  v.] 
?  safe  level)  requires  two 

"only  Alternative  8  reaches  I  1  svel  alt--. 

Alternatives  6  and  7  ercent 

lent  level  accord     to  Table  3-10. 
be  to  liberal,  as  the  old  Alter:. 


was  within  3  and  4  KH3I  of  Alternatives  7  and  6  was  previously 
described  to  offer  only  "a  cavity  dweller  population  at  40 ■  of 
maximum  potential  throughout  the  District".   According  to  Jack  16-32 

rhomas,  'lldllfe  Habitats  In  l.anaged  Forest,  40:  is  the 
very  bottom  of  the  "viable"  range.   Ihls  level  of  cavity  nester 
population  would  be  dangerously  close  to  not  being  able  to  main- 
tain self-sustaining  populations.   We  therefore  can  not  feel  com- 
fortable In  your  conclusion  that  Alternatives  6  and  7  are  "close" 
enough,  especially  when  "District  surveys  regaled  that  snags  and/ 
or  wildlife  trees  are  being  provided  at  the  rate  of  0.1  per  acre 
on  recent  harvest  units." 

-cent  Solicitor's  review  has  stated  "that  the  OiC  legislation 
is  a  conservation  measure  requiring  a  form  of  multiple  use  manage- 
ment" and  "further,  the  Act  clearly  does  not  mandate  exclusive  use, 
but  Instead  requires  management  for  other  Interest  as  well  as  tim- 
ber supply."  The  Law  of  i.arch  29.  1944  further  solidifies  3L;.'s 
commitment  to  multiple  use  management.  Ihls  lav;  provided  the  Sec- 
retary of  Interior  with  the  authority  to  set  up  cooperative  sustain- 
ed yield  units  to  among  other  things  "secure  the  benefits  of  forest 
in. . .preservation  of  wildlife..."  (16  U.S.C.  583)   Yet  In  recom- 
mending the  protection  of  only  18  pairs  of  northern  spotted  oi 
to  be  maintained  (under  the  30C  "cro  prescription)  of  the  55  pairs 
known  to  presently  occur  on  the  district,  BLM  has  ione  an 
job  at  fulfilling  It:         oal  to  keep  the  spotted  owl  off  I 
federal  endangered  list. 

lollcltor's  :         tes:  "In  the  case  of  those  areas  of  land 
direct  conflict  in  use  will  occur,  the  bureau  may  choose  one 
use  over  the  other,  provided  It  has  analyzed  its  choice  in  the  eon- 
text  of  the  principle  goals  of  each  Act  and  is  satisfied  that  the 
particular  choice  has  not  significantly  encroached  upon  the  overall 
effect  of  those  goals."  pnrtment  of  Fish  and 

life  has  stated  that  Roseburg' s  contribution  to  the  Spotted  Owl 
Management  Plan  is  essential  in  providing  a  connection  that  will 
assure  genetic  vlablllv         .  spotted  owl  populations  on  the 
coast  and  in  the  Case  recommending  less  habitat  (and 

number  of  pairs)  for  spotted  owls  In  your  preferred  alternative,  16—35 

then  was  recommended  be  provided  by  the  Endangered  Species  Task  ,w  ^ 

Force,  you  will  be  severiy  Jeopardizing  the  viability  of  this 
species.  Any  alternative  which  would  reduce  existing  old  growth 
on  the  Roseburg  District  from  110,900  remaining  acres  to  Just 
28,400  in  Just  three  decades  is  clearly  a  "significant  encroachment 
upon  the  overall  effect"  of  this  particular  multiple  use  goal. 

In  Pabltat  Diversity  For  Wildlife  On  3LH  nanaaed  Lands  In  Western 
Orejon  (revised  October  1981)  It  is  stated  that  If  15,.  of  PL:. 
lands  were  retained  In  mldage  and  old  growth  forest,  minimum 
habitat  diversity  requirement  could  be  met.   Yet  out  of  Roseburg 
eiLi.'s  424,000  managed  acres,  all  totaled,  less  than  9f   (38,000  acres) 
would  be  provided  as  habitat,  in  the  preferred  alternative,  for 
species  which  prefer  old  growth  areas — countlns  scenic  corridors 
and  marginally  protected  stream  buffers.   As  this  Is  wholly  un- 


acceptable to  us,                     :ore  full;  your 

choice"  and  ssue  of  how  these  less  lounts 

of  acreage  '.rill  "secur        .  Pits  of  for      .  .  -  tlo.n 
lldllfe"? 

address  the  follovln.  question! 
«  on  Ithe  nortiurn  spotte-:  owl.   What  does  t 
ID  OO   |  *,  -..  (or 

lack  of  it'  with  the  Department  of 
recommendations  of  the  En  .      - 

: 


. e  shown  the 
r  until 

ot  th"! 

llity  to  " 

i 
rotation  than  th. 

continually  provl 


16-3 


. 

er  acr 

acre? 
f.e  of 

Iso 
I 


4 


on  i able  ')-■   ,  '•... 
Land  (To  ' 

native  ■'■  . 
1  thru  result  in 

■ 
.  00  tons,  o! 
In  our  .: 

llty  prob: ,. 
re  sedimentation  (13  out  of  17); 
temperatures  (16  out  o: 

Sow  can  the  SLi:  claim  that  Alternatlv 

nlflcantly  less 
tons/decade,  a  difference  of  4,40?  tonsl   :iow  can  cal- 

culate the  difference  t  el  of  con- 

fidence to  enable  your  claim?  Especla]         ju  concede 

Le  soils  are  found  throughout  th 
that  "these  soils  Include  3?.  ranltic  soils  or  other 

soils  that  ntial  for  mass  failure  and  135,711 

acres  of  soils  on  very  stee  1th  Inclusion  of  unsta 

Us."*   Yet  the  preferred  alternative  would  commit  333.319 
acres  of  commercial  forest  land  to  Intensive  timber  management 


Ls  totals  172.253  acres  of  unstable  soils.   If  this  is  sub- 
tracted from  BLI.'s  total  acreage  of  424,000,  251, 74^  acres  of 
stable  land  remains.  This  is  interesting  to  cr  the 

262,436  acre  timber  base  recommended  under  alternative  8  that 
would  still  produce  84  ,.,-.3F  per  year. 


106 


-13- 


16-36 


16-37 


and  an  additional  52.2**?  acres  to  be  managed  under  what  Is 
called  "modified  area  control" — (which  still  permits  timber 
harvest  In  riparian  buffers).   Studies  on  I 
District  show  that  landslides  In  Tyee  sandstone  Increase- 

•ibove  the  undisturbed  forest  rate  following  clenrcuttlng 
and  roadbulldlng  (according  to  the  DEIS).  Yet  according  to  the 
BLl'.'s  5  year  timber  sale  plan,  "4600  acres  of  these  soils,  ldent- 

18  fragile,  would  be  harvested." 

It  Is  ridiculous  to  assume  that  Alternative  4  will  produce  as 
positive  gains  for  fish  populations  in  comparison  with  Alternative 
8 — the  letter,  which  by  your  figures,  wouldn't  even  produce  1/10 
the  sediment  load.   Also  "should  design  features  fall,  portions 
of  streams  could  be  adversely  Impact.  Is  their  probability 

of  failure?  Aj-._  the  tons  of  sediments  per  decade  for  each  alter- 
native figured  without  including  the  additional  Impacts  of  possible 
failures? 

Under  "environmental  Consequences"  page  77.  the  author  attributes 
the  impact  of  timber  management  on  fish  populations  and  discusses 
the  Importance  of  maintaining  buffers  to  protect  "the  habitat  of 
aquatic  Invertebrates,  which  are  Important  both  as  food  for  fish 
and  as  Indicators  of  stream  quality."   "On  lands  administered  by 
BLK  in  the  SYUs  there  are  approximately  270  miles  of  streams  that 
support  cold  water  fish."  Analysis  of  the  sample  5-year  timber 
sale  plan  shows  that  approximately  "17  miles  of  stream  that  sup- 
port cold  water  fish  pass  through  or  are  adjacent  to  77  harvest 
units."  The  author  falls  to  draw  the  obvious  conclusion  of  what 
additional  affect  stream  warming  will  have  on  fish  populations 
under  the  preferred  alternative.  The  conclusion  on  page  79  how- 
ever states,  "If  it  is  assumed  current  fish  populations  reflect 
conditions  and  harvest  regulations  over  the  past  decade,  then  It 
can  be  assumed  that  fish  populations  would  decline  under  Alter- 
natives 1  through  3  due  to  Increased  teaoeratures  and  sedimentation." 
"Fish  would  Increase  In  Alternatives  4,6,7,  and  8  and  remain  the 
same  under  Alternative  5." 

It  Is  hard  to  see  how  they  will  remain  the  same  under  the  No' 

Alternative  5  "If  It  Is  assumed  current  fish  populations 
(which  are  not  high)  reflect  conditions  and  harvest  regulations 
over  the  past  decade"  and  as  explained  on  page  78,  since  Alter- 
native 5  makes  "no  provision  for  riparian  buffers" .. ."water 
temperatures  would  increase  greatly."  On  page  68,  the  forcasted 
sediment  loads  of  Alternatives  6  and  8  don't  even  come  close  to 
the  magnitude  of  other  alternative's  sediment  loads.  Including 

ntlves  4  and  7.   It  is  difficult  to  see  how  either  Alternative 
4  or  7  coul  ted  to  provide  fish  populations  that  would  do 

anything  but  decline.   It  Is  amazing  that  BLii  thinks  that  a  sediment 
load  of  281,300  tons  (Alt.  3)  will  decrease  fish  populations,  but  a 
a  projected  sediment  load  of  only  slightly  less  (272,800  tons  under 
Alt.  4),  will  Increase  fish  populations.   On  page  18  It  states 
Alternative  4  allocated  the  same  acreage  to  timber  as  Alternative  3. 
Also  "management  elements  would  be  the  same  as  Alternative  3" — 
under  which  "fish  populations  would  decline." 


16-38 


12.  The  SIS  states  that  "Alter,,  tl       -ovldes  temperature  aal  • 
ror  first  order  and  larger  str    .   ,-.  -natives  1 

removal  of  merchantable  timber  would  reduce  thi  rieao  of 

buffers  to  provide  adequate  shade  resulting  In  lncr 
tures."  Also  "downstream  shading  do-  Iflcantly  lower 

temperatures  of  streams  warmed  by  upstrea  .  al. 

1971)."  Since  the  tons  of'Sedlment  Produced  Through  prop,. 
In  lable  3-5  Is  only  again  slightly  less  for  Alternative  4  than 
Alternatives  J   and  5,  why  should  „e  not  also  assume  that  Alter- 
natives 2,  3  and  4  will  also  raise  stream  temperatur  ;iy 
the  data  shows  that  the  magnitude  of  this  Impact  will  be  even 
greater  In  Alternative  2  than  5? 

Also  we  would  expect  fish  success  to  decline  under  the  preferred 
alternative  because  "oxygen  concentrations  In  stream  gravel  may 
continue  to  decline  for  several 

flow  through  gravels  Is  restricted  by  sedimentation  (.-all  and  Lantz 
19&9)."  And,  "for  this  reason,  Impacts  on  lntragravel  oxygen  in 
the  SYU's  would  be  directly  related  to  the  change  In  sediment  s 
discussed  above"  ( pa^e  69). 


Also  this  same  sediment  yield,  which 
the  natural  rate  (undisturbed  condlt 
with  roads  (Fredrlksen  and  Karr  1979 
any  measurable  increases  In  summer  1 
research  done  by  Denlse  :;arr  of  the 
you  can't  count  increased  low  flows 
increase  In  flows  are  going  to  be  le 
on  the  larger  streams,  and  will  be  1 
uatlon  of  the  larger  streams. 


to  be  "23  tl 
Ion)  in  a  patch  cut  waters! 
)" ,  could  absorb  and  contain 
ow  flow  levels.   According  to 
Forestry  Science  Lab  in  Corvallls, 
as  a  benefit.  Any  hypothetical 
ss  than  your  ability  to 
ess  than  the  year  to  year  fluct- 


13-  Other  research  by  Pedell,  Everest  and  swanson  at  the  pacific  .iorth- 
west  Forest  and  liange  Experiment  Station  have  E         "-uldellnes 
for  future  practices  that  will  best  preserve  and  restore  both  physical 
and  biological  Integrity  in  streams  ecosystems"  (Fish  Habitat  and 
Streamslde  ,,anagment  fast  and  Present)  .   Four  key  structural  com- 
ponents are  to  provide  "(1)  large  live  trees  In  riparian  zones,  (2) 
large  snags,  (3)  large  logs  on  the  flood plain,  and  (4)  large  snags 
and  large  organic  debris  in  the  stream."   "Organic  debris  in  streams 
Increases  diversity  of  aquatic  habitat  by  forming  oools  and  protected 
backwater  areas,  serves  as  a  source  of  nutrients  and  substrate  for 
biological  activity,  and  affect  sediment  movement  and  storage  by 
dissipating  energy  of  flowing  water  and  trapping  sediment."' 

Alternatives,  other  than  #8  would  not  provide  these  conditions. 
Page  75  of  the  DEIS  states  that  "management  by  modified  area  control 
as  proposed  In  Alternatives  2,3,4  and  7  would. . .substantially  alter 
riparian  habitats." 

Of  the  Hoseburg  BLi'.'s  424,000  acres  only  22,800  acres  consist  of 

riparian  habitat  yet  "riparian  habitat  is  Important  as  88  percent 

of  the  terrestrial  wildlife  species  in  the  area  use  it  to  some  degree." 


-14- 


-15- 


16-39 


14. 

16-40 


Yet  in  seven  out  of  eight  BLK  alternatives  buffers  are  provided 
only  along  streams  (200  feet  wide  in  most  cases)  that  are  third 
order  or  greater.   According  to  the  DEIS  this  makes  up  only  about 
3  percent  of  the  forest  land  base."  An  additional  12,150  acres  of 
small  first  and  second  order  streams  would  only  receive  protection 
under  the  Full  Ecosystems  Alternative,  Alternative  8.   In  addition, 
page  45  of  the  DEIS  concedes,  that  even  along  3rd  order  streams 
"some  of  this  has  been  altered  by  past  timber  management  practices 
and  Is  In  less  than  optimum  condition." 

Oregon  Administrative  Rules,  Chapter  340,  State  Water  Quality 
Law  for  the  I'mpqua  Basin  and  the  Clean  Water  Act  of  1972,  as 
amended,  specify  that  no  temperature  Increases  are  allowed  on 
streams  that  are  above  58°  Fahrenheit,  and  federal  agencies  are 
bound  to  that  state  standard.   How  will  the  preferred  alternative 
prevent  temperature  Increases  when  Table  2-5  "Severe  '.later  Quality 
Problems"  Indicates  that  16  of  17  major  streams  in  the  Hoseburg 
District  already  have  "elevated  water  temperatures?"   Sediment 
yield  or  turbidity  is  limited  to  10S  Increases — how  can  full  timber 
harvest  be  allowed  on  first  and  second  order  streams  with  the 
Increased  possibility  of  landslides  when  roots  die  in  seven  to  ten 
years? 

In  the  FEIS  please  provide  some  explanation  of  the  allowable  cut 
calculation.   What  assumptions  must  be  made  to  Increase  present 
harvest  levels?   If  any  assumptions  are  being  made  which  lack 
sufficient  documentation,  then  the  FEIS  should  explain  the  rational 
for  using  these  assumptions. 

I  What  would  be  the  cost-benefit  ratio  for  various  intensive  manage- 
ment practices  If  you  did  not  take  a  credit  for  cutting  existing 
old  growth,  but  rather  figured  the  allowable  cut  effect  (ACE)  Just 
assuming  reforestation  alone? 

A  risk  factor  should  be  figured  Into  calculating  the  allowable  cut. 
The  FEIS  should  state  what  the  risk  would  be  for: 

a.  drops  in  biological  potential  due  to  fire  or  disease.   (The  EIS 
should  also  describe  what  forest  diseases  presently  exist  on  the 
Roseburg  District.) 

b.  drops  in  biological  potential  resulting  from  overly  optimistic 
projections  of  growth  increase  resulting  from  intensive  management. 

c.  inability  to  carry  out  management  programs  because  of  financial 
squeezes  or  contract  failures.   (If  a  key  assumption  of  the  allowable 
cut  calculation  Is  that  sufficient  funding  and  personnel  will  be 
available  for  the  lmpllmentatlon  of  the  final  decision,  then  the 
FEIS  should  Include  a  list  of  priorities  should  funding  fall  below 
the  accustomed  levels.) 

Table  1-5,  "Summary  of  Impacts",  provides  a  somewhat  distorted 
picture  of  net  Job  losses.   Besides  being  based  on  a  set  of 
assumptions  not  fully  explained  in  the  DEIS,  future  employment 
pictures  might  be  more  accurate  if  they  were  based  on  present 
trends  In  the  Industry  for  the  entire  southern  Oregon  area  coupled 
with  the  reality  that  the  "building  boom"  days,  facilitated  by  low 
mortgage  rates,  are  gone.   Also,  if  Instead  the  per  cent  of  total 


16-42 
16-43 

16-44 


Job  losses  from  BLK  alternatives  were  compared  with  projected 
declines  in  all  areas,  a  more  accurate  picture  would  be  portrayed, 
rather  than  to  basically  Just  single  out  BLr.'s  contribution. 
Previous  studies  have  shown  that  the  southern  Oregon  counties 
are  net  exporters  of  timber.   Apart  from  the  present  recession, 
as  long  as  mill  capacity  is  above  supply,  there  will  be  Job  losses 

I  in  the  timber  industry.   The  FEIS  you  write  should  acknowledge 
these  facts  and  estimate  what  the  Job  potential  would  be  If  more 
of  this  timber,  presently  exported,  were  kept  cycling  through 
the  local  economy. 

15-  We  find  the  discussion  of  Impacts  on  recreation  ludicrous.  The 
DEIS  states  that  "opportunities  for  such  activities  as  camping, 
hiking,  fishing,  hunting,  nature  study  and  slghtseelnj  would  be 
degraded  in  some  areas."  Yet  "clearcuttlng"  somehow  balances 
this  by  providing  "opportunities"  for  " olcknlcklng" ,  "using  ORV's" 
and"provldlng  openings  for  scenic  views."   r.aking  a  clear  cut  to 
provide  a  scenic  view,  would  be  like  blowing  a  hole  In  the  roof 
of  your  living  room,  to  better  facilitate  seeing  the  stars. 
Furthermore,  there  are  presently  12,000  acres  of  roads  on  the 
Roseburg  BLK.   This  Is  presently  more  acres  of  roads  than  Alter- 
native 5,  the  .io   Change  Alternative,  would  provide  In  acres  of 
old  growth  in  Just  a  little  over  20  years  (see  Table  3-9  page  73). 
In  addition  the  DEIS  states  "In  Alternatives  1,2,3,  &  4  road 
building  during  the  decade  would  be  more  than  in  the  past  decade." 
It  seems  the  ORV  opportunities  are  going  to  be  more  than  adequately 
provided  for  in  proportion  to  opportunities  for  hiking  and  nature 
study  In  an  aesthetlcly  pleasing  environment.    Ihe  DEIS's  reference 
to  clear  cuts  providing  "plcknlcklng"  oportunltles  does  not  deserve 
further  comment. 

We  also  resent   the   assumption  that  "some  visitors  may  relo- 
cate to  other  areas  where  opportunities  for  desired  experiences 
exist."  The  point  Is,  at  the  rate  we  are  manipulating  and  alter- 
ing our  forest  and  other  natural  places,  there  will  simply  be  few 
places  left  to  go  where  the  hand  of  man  hasn't  already  marred  the 
earth.   We  disagree  with  the  statement  on  page  81  that  "Alternatives 
2,3,4  and  7  would  be  satisfactory  "In  meeting  the  demand  for  hiking". 
Especially  when  you  lump  the  hiking  experience  with  "horseback 
riding  and  off- road  vehicle  areas  and  trails."  Also,  some  horse- 
back riders  may  prefer  bridle  trails  that  offer  a  greater  aesthetlc- 
ly pleasing  experience  than  what  can  be  afforded.  In  the  above 
mentioned  alternatives,  from  a  tractor  road  through  a  clear  cut. 

Our  forests  should  be  managed,  but  not  exploited.   We  need  to  re- 
move forest  products  to  meet  human  needs,  but  not  at  the  total  ex- 
clusion of  all  other  creature's  needs.   Both  house  of  Congress 
recently  demonstrated  their  concern  by  an  overwhelming  unanimous 
reauthorization  of  the  Endangered  Species  Act.   We  don't  believe 
that  the  American  public,  represented  by  our  Congress,  accepts 
the  management  of  our  forest's  resources  by  an  agency  whose  manage- 
ment direction  openly  Implies  and  reports  the  future  degradation 
of  our  wildlife,  our  watersheds,  and  our  remaining  old  growth 
forests. 


-16- 

Slncerely , 
Umpqua   Valley  Audubon   Society    aoard   of   Directors 


107 


0\  Qiyv%AMC^>j6U^v^x-^ 


Response  to  comments  in  Letter  16 


16-1         No  allowable  cut  credit   is  tak 

manual   release  methods  of   vegetation  control.   Refer  to  DEIS, 
Appendix  C,  Allowable  Cut  Effect,  page  127.  Also,   see  i 
cannon  issue  3. 

16-2         Alternative  4  in  the  DEIS  is  tl 

MFP  preferred  alternat.  <■ 

difference  in  volume  is  the  r 

the  allowable  cut  calculation. 

16-3        Alternative  8  is  the  wildlife  alternative  which   in 
allocated  for  int  t  management   | 

Appendix  C,  Table  C-2. 

16-4         The  Roseburg  District  Young  Growth  Management  Cam 
(available  at  the  Roseburg  District  Office),   add: 
management  techniques  incorporated   in  the  Roseburg  D: 
along  with  rationale,   assumptions  and  lit   i 

gains  associated  with  such  practices  are  represented  by  DFIT  (see 
response  to  comment  16-20).  Scheduled  monitoring  will  examine 
of  intensive  practices  as  described   in  the  DEIS,  Chapter  1,   p  ■ 


16-5         The  harvest  level   for  all   alternatives  is  computed  to  be  sustainable 
for  400  years.  Refer  to  DEIS     Appendix  C,   page  127.  Fish 
recreation  and  other  water  dependent  activities  are  expected  to  be 
sustainable. 


16-6         See  response  to  comment  16-3. 

16-7         See  response  to  comment  5-1. 

16-8         Timber  harvest  method  alternatives  and  their  influence  on  soil 

erosion  and  compaction  are  discussed  in  detail  in  Chapter  III  1975, 
Timber  Management  Final  Environmental  Impact  Statement,  incorporated 
by  reference  in  the  EIS 

The  silvicultural  validity  and  cost  effectiveness  of  clearcutting  and 
intensive  reforestation  vs.  shelterwoods  are  discussed  in  a  Roseburg 
District  study,   "Use  of  Artificial  Shade  to  Increase  Survival  of 
Douglas-fir  in  the  Roseburg  Area"   (Wert  and  Lewis  1977).  This  study 
is  available  for  review  at  the  Roseburg  District  Office. 

16-9         In  the  Roseburg  SYUs  first  and  second  order  streams  are  normally  dry 
except  during  peak  flow  periods.  Nutrient  concentrations  following 
slash  burning  will   normally  not  exist  during  flow  periods-   therefore, 
impacts  to  water  quality  are  not  significant.  Also,  see  text  revision 
in  FEIS,  Impacts  on  water  Resources,  Water  Quality  section. 


16-10       The  Roseburg  District  has  been  monitoring  herbicide  operations  for 
several  years.  This  includes  testing  a  number  of  water  samples.  All 
of  the  test  results  have  indicated  either  no  herbicide  residue  or 
levels  of  herbicides  well  within  set  standards.  Results  are  available 
at  the  Roseburg  District  Office. 

16-11       The  statement  on  page  87  of  the  DEIS  was  in  error  and  has  been 
removed  from  the  FEIS. 

16-12       Evidence  examined  by  EPA  in  the  2,4-D  registration 
recently  summarized  by  Frank  Dost  et  al .    (SQCATS 
Court  in  Portland  indicates  no  significant  human  health  hazai 
silvicultural    application  of  2,4-D.  This  finding  has  be 
by  Drs.  Melvin  Rueben  and  Ruth  Shearer,  both  of  whan  believe  that  any 
human  exposure  to  2,4-D,     regardless  of  how  smal  the 

amount,  presents  a  significant  hazard  to  human  health. 

16-13       Roseburg  District  has  conducted  several  cost  studies  associated  with 
vegetation  management  practices.  Data  are  currently  being  collected 
for  each  vegetation  management  practice.  These  data  are  being  used  in 
the  new  Vegetation  Management  EIS,   scheduled  for  completion  later  in 
1983. 


16-14       Long-term  impacts  to  forest  soils  were  judged  to  be  insignificant 

because  the  nitrogen  increase  caused  by  fertilization  will   readily  be 
eliminated  by  plant  adsorption,  volatilization  and  microbial    action. 


108 


16-15       See  response  to  ocmment   15-7. 

16-16       Impacts  from  fertilization  on  genetically  improved  trees  are 

presented  in  the  DEIS  Chapter  3  Impacts  on  Vegetation  section  page 
70.  No  adverse  impacts  on  genetically  improved  trees  are  expected  to 
occur 

16-17       Same  recent  forecasts  indicate  that  energy  supplies  may  be  abundant 
for  years  to  come. 

16-18      The  Regional  Forest  Nutrition  Research  Project  has  been  studying  the 
effects  of  forest  fertilization  in  southwest  Oregon  for  over  10 
years.  There  are  seven  study  plots  in  the  BLM  Roseburg  District.  This 
research  project  is  being  conducted  by  the  Pacific  Northwest  Forest 
and  Range  Experiment  Station  and  the  University  of  Washington. 
Results  of  the  study  indicate  that  cubic  feet/acre/year  increases  in 
tree  growth  commonly  exceed  the  11  percent  gains  in  the  district's 
allowable  cut  model.  Additional    information  is  available  at  the 
Roseburg  District  Office. 

16-19       Fertilizer  application,  according  to  the  district's  management 
regime,  would  not  replace  the  volume  of  soil   nutrient  loss  from 
clearcutting  or  burning;   however,   fertilization  provides  an  average 
timber  volume  increase  of  11  percent  over  natural  production  yields. 
Thus,  overall  soil  productivity  is  increased  over  natural   levels 
through  fertilization. 


16-20      The  concept  of  "piggybacking"  intensive  practices  ia  controversial. 
This  controversy  steins  from  a  lack  of  research  on  the  cumuli 
effects  of  applying  various  combinations  of  intensive  practices  to 
stands  of  varying  site  quality  over  the  length  of  a  harvest  rotation. 

Although  long-term  research  is  lacking,  research  of  shorter  duration 
has  produced  much  data.  The  authors  of  DFIT  feel   that  data  I  -   i 
short-term  research  can  be  safely  extrapolated  into  the  future.   (DPIT 
is  the  managed  Douglas-fir  stand  yield  simulation  model  developed  at 
the  USFS  Pacific  Northwest  Forest  and  Range  Experiment  Station  to 
project  future  growth  under  various  intensive  management  schemes.) 

In  developing  the  DFIT  model,  the  best  available  information  was  used 
to  simulate  the  combined  effects  of  intensive  practices.  BLM  has 
adopted  DFIT,  with  certain  adjustments,  as  an  acceptable  estijnator  of 
future  managed  stand  yields.  Also,   see  response  to  common  issue  3. 

16-21       Refer  to  DEIS,  Appendix  B,  Table  B-8.  The  analysis  of  differing 
minimum  harvest  ages  notes  that  under  most  conditions,  the  net 
present  value  of  the  forest  decreases  with  an  increase  in  minimum 
harvest  age.  Yields  displayed  in  all  alternatives  are  sustainable. 

16-22       Two  thousand  two  hundred  twenty-six   (2,226)  acres  of  recent  clearcuts 
awaiting  site  preparation  are  currently  non-stocked.   Four  hundred 
sixty-seven  (467)  acres  of  brush  and  hardwood  conversion  areas  await 
initial  planting.   Five  thousand  fifty-nine  (5,059)   acres  of  partial 
reforestation  faUures  are  currently  understocked.  These 


reforestation  delays,   as  well   as  successes,  are  accounted  for  in  the 
"Reforestation  Lag"  time  input  to  the  allowable  cut  calculation. 

Many  studies  specific  to  the  utility  of  the  proposed  intensive 
management  practices  on  the  Roseburg  District  are  cited   in  the  Young 
Growth  Management  Committee  Report   (1979b).  Additional  local  studies 
attesting  to  the  effectiveness  of  the  practices  are  available  in  the 
district  office. 

One  hundred  percent  planting  of  harvested  lands  is  planned. 
Gratuitous  seed   from  an  adjacent  source  is  not  necessary  to  achieve 
district  goals  but  would  certainly  contribute  toward  reaching  the 
stocking  standards   if  it  occurred. 


16-26       The  Research  Natural  Area  Committee  originally  identified  the  Bear 

Gulch  parcel   as  a  needed  cell   for  the  western  Cascades  physiographic 
province.  The  committee  later  indicated  the  cell  was  within  the 
Klamath  Mountains  or  Siskiyou  province,    for  which  the  Roseburg 
District  has  no  responsibility. 

16-27       See  response  to  comment  5-2. 

16-28       BLM's  conclusions  regarding  consistency  with  Statewide  Planning  Goals 
were  developed  through  consultation  with  Department  of  Land 
Conservation  and  Development  staff. 

16-29       See  response  to  comment  7-1. 


Good  site  preparation  and  site  maintenance  are  requirements  of  a 
successful   reforestation  program. 

16-23       See  response  to  common  issue  3  and  comment  4-3.  The  Roseburg  District 
Young  Growth  Management  Committee  Report  addresses  the  viability  of 
the  tree  improvement  program. 

16-24       BLM  has  made  no  assumptions  as  to  reforestation  methods  on  adjacent 
private  lands.  Appendices  E  and  F  illustrate  that  BLM  plans  are  not 
going  to  significantly  alter  stand  structure  in  the  EIS  area,   as 
related  to  the  tree  improvement  program. 

16-25       See  revised  text,   FEIS,  Chapter  3,   Impacts  on  Vegetation  section,   for 
a  more  comprehensive  discussion  of  this  issue. 


16-30       The  effect  of  the  transportation  system  on  State-listed  species  can 

be  quantified  to  the  extent  the  given  alternative  provides  protection 
for  selected  owl  pairs.  The  primary  effect  on  the  spotted  owl  would 
come  from  harvest  unit  placement.  Because  road  development   is  part  of 
an  overall  harvest  action,  roads  are  assumed  to  affect  the  owls  in 
the  same  manner  as  the  harvest  units  when  in  proximity  to  owl 
habitat. 

With  regard  to  federally  listed  species,   i.e.,  the  bald  eagle,   it  is 
assumed  that  compliance  with  the  Endangered  Species  Act  and  the 
development  of  Habitat  Management  Plans  (on  the  lands  allocated  for 
the  eagle)  will   assure  that  no  adverse  conflicts  between  the 
transportation  system  and  the  species  habitat  will  occur. 


109 


16-31       Every  effort,    including   appropriate  season  field  examinations,    is 
made  to  become  reasonably  certain  that  there  are  no  impacts  to 
federally  listed  threatened  and  endangered  plants  or  those  under 
review  for  federal  listing.  Guidelines  for  botanical  surveys  are 
given  in  Instruction  Memorandum  Roseburg  81-22. 

16-32       As  stated  in  the  DEIS,  Chapter  3,   Impacts  on  Animals  section,  not 

every  alternative  may  provide  habitat  for  all  wildlife  species  in  the 
long  term.  Also,   see  response  to  cannon  issue  1  and  comment  12-1. 

16-33       Based  on  the  direction  provided   in  the  the  new  O&C  Forest  Resources 
Policy  (Appendix  A),  the  BLM  will   not  actively  pursue  a  management 
plan  to  yield  any  specified  population  level    for  spotted  owls. 


16-35       Conclusions  on  sediment  yield  for  each  alternative  are  compared 
against  the  existing  situation.  Alternative  5  represents  data 

loped  from  the  previous  planning  process,  which   is  not 
necessarily  comparable  with  this  plan.  Based  on 

calculation.  Alternative  4   is  determined  to  ■  •rimental    than 

Alternative  5.   However,   the  degree  of  significance  and  level    of 
precision  are  difficult  to  calculate  with  a  high  level    of  con! 


16-36       The  probability  of   failure  cannot  be  precisely 
properly  designed  and  constructed  pro: 
failure.  Specific  practices  are  subject  to  char 


xi  mon 


and  results  of  new  research.  Th  roth  the  DEIS 

and  FEIS  does  not  address  the  possibility  of  design   fail 


An  assessment  of  the  effect  this  approach  has  on  species  viability 
statewide  is  included  in  the  FEIS,  Conclusions  section.  Chapter  3, 
under  Impacts  on  Animals.  Also,  see  response  to  comment  83-6. 

16-34      The  conclusions  reached  on  page  79  of  the  DEIS,  Table  3-6,   are  based 
on  changes  in  temperature  and  sediment  compared  to  the  existing 
situation. 


16-37       The  text  has  been  revised  to  indicate  that  a  vegetative  buff 
be  maintained  in  Alternative  5.   In  the  EIS,  Alternative  5  is 
considered  to  be  a  continuation  of  the  plan  for  the  1970s  and  a 
reflection  of  the  existing  situation.  Research  by  Hall   and  Lantz 
(1969)   indicates  that  increases   in  fine  sediments  to  spawning  beds 
can  decrease  the  permeabil  ity  of  spawning  gravels,    af  f^  - 
survival  of  salmonid  embryos  and   impeding  emergence  of   fry.    Increases 
in  sediments  over  the  existing  situation  {Alternative  5)  would  result 
in  decreases  in  fish  population,  while  decreases   in  sediment   from  the 
existing  situation  (Alternative  5)  would  result  in  more  favorable 
habitat  capable  of  supporting   increased  fish  populations.   Prom  this, 
it  can  be  assumed  that  fish  populations  would  be  greater  in 
Alternatives  6,  8,  or  9  than  in  Alternatives  4  or  7. 


16-38       Buffers  for  sediments  and  for  shade  are  two  separate  things.  Shade 
over  third  order  and  larger  streams  is  provided  in  all  alternatives. 
Because  Alternative  1  permits  timber  harvest   in  the  streamside 
buffers     which  would  reduce  shade,   stream  temperatures  are  expected 
to  increase  under  that  alternative.  Harvest  in  riparian  areas  on 
first  and  second  order  streams  is  not  expected  to  increase 
temperatures  as  those  streams  are  usually  dry  in  the  summer. 


16-43       Yield  projections  for  intensive  management  practices  are  based  on 

current  research  and  are  adjusted  to  operational   levels.  Yield  gains 
from  intensive  management  practices  are  reduced  to  account   for 
physical  variables  which  differ  from  controlled  research  and  which 
are  below  ultimate  biological   potential.  These  factors  are  bui 
the  allowable  cut  computation  (refer  to  DEIS,   paqe  127).  Also,    see 
response  to  comments  16-22  and  16-23. 


16-39  Chapter  340,  State  Water  Quality  Law,  states  that  forest  management 
activities  shall  be  in  accordance  with  the  Oregon  Forest  Practices 
Act.  Also,  see  response  to  comment  15-6. 

16-40       The  allowable  cut  computation  process  is  discussed  in  the  DEIS, 

Appendix  C,   page  127.  Prescribed  management  treatments  are  described 
in  the  EIS,  Chapter  1  and  summarized  on  Tables  1-2.  Also,  see 
response  to  common  issue  3. 

16-41       There  is  no  allowable  cut  effect  for  reforestation  alone.  Refer  to 

DEIS,  Appendix  C,  page  127   for  discussion  of  the  Allowable  Cut  Effect 
(ACE) . 


16-44       See  response  to  common  issue  2. 

16-45       Table  2-17  of  the  EIS  reports  rates  of  change   in  lumber  and  wood 
products  employment   for  Douglas  County,    the  regional  economy 
(Douglas,  Lane,  Coos,  Josephine,   and  Jackson  counties)   and  Oregon  for 
the  period  1972-1980.  The  text  on  page  54  of  the  DEIS  cites  I 
reports  which  make  projections  about  employment   in  lumber  and  wood 
products  manufacturing.  The  FEIS  displays  the  impacts  on  the  human 
environment  of  an  array  of  alternate  timber  management  programs 
available  to  the  Roseburg  District  of  the  Bureau  of  Land  Management. 
It   is  beyond  the  scope  of  the  FEIS  to  evaluate  alternative  federal 
policies  on  international  or  interregional  log  export. 


16-42       In  the  event  of  a  natural  disaster,   such  as  fire,     blowdown,  disease 
or  insect  attack,   the  salvable  volume  harvested  would  be  substituted 
for  the  normally  planned  clearcut  volume.  No  other  safety  or  risk 
factor  is  built   into  the  allowable  cut  determination  process. 
However,    if  a  disaster  were  extensive,   a  recalculation  of  the 
allowable  cut  could  be  made  before  the  normal   10-year  recalculation. 


i         d  States  1  >epartment  ol  the  Interior 


1202-03  (PNR-RE) 

Roseburg  Timber  Management 

DEIS 

August  12,  1982 


\A1  II  IN  \l     PARK    SI  K\  II    I 
Pai  iih  Northwcut  Region 


32 


Response  to  comments  In  Letter  32. 

32-1    Ihis  kind  of  analysis  would  be  applied  to  Individual  timber  sales  and 
detailed  in  environmental  assessments  when  such  conflicts  are 
identified. 


To:      District  Manager,  Bureau  of  Land  Management,  Roseburg  District 
Office 

From:    Associate  Regional  Director,  Recreation  Resources  and 
Professional  Services,  Pacific  Northwest  Region 

Subject:  Roseburg  Timber  Management  Draft  Environmental  Impact 
Statement 

Our  comments  on  the  subject  document  are  provided  below: 

The  proposed  protection  of  cultural  and/or  historic  resources  is  very 
satisfactory.  However,  we  have  some  concern  about  the  way  in  which  the 
impacts  on  recreation  are  described.  It  is  stated  that  "timber  harvest 
in  the  vicinity  of  potential  hiking  and  equestrian  trails  would  degrade 

I  the  recreation  experience  ..."  While  this  may  be  so,  it  might  be 
stated  that  if  timber  harvest  is  planned  in  the  vicinity  of  potential 
hiking  and  equestrian  trails,  attempts  will  be  made  to  keep  the  impacts 
upon  the  recreation  experience  to  a  minimum. 

We  realize  environmental  assessments  will  be  prepared  prior  to  each 
timber  sale  and  that  these  documents  will  provide  more  specifics.  We 
will  look  forward  to  reviewing  the  assessments. 

Thank  you  for  the  opportunity  to  comment. 


/£j*uL£ft£fc- 


Richard  L.    Winters 


33 


-2- 


^1  chard    Chasm 
P.r.    Pox    51 
Dlllard   C=,    9TW2 
16,    Aug.    1982 

Kr,    Jim  Hart,    District   .-.anager 

Bureau   of  Land  hanage:, 

.,.   Garder    Valley  Blvd. 

Roseburg   OR,    ,:^47C 

Dear  Kr.  Hart, 

After    several   weeks   of   careful    reading   and    study   of   the 
.  a-ao-eme-t   Draft   SIS,    lifould    like   to    submit   the 
following    comments.      I    realize  at   the   p-ese"t   tltre  we'dlscusslm    th» 
adequacy   of   this    document   to   prepare   the   final    51?    Borne    time    -  ext   year. 

After  years  of   nlar'lna   document?    from   the   county,    stat<>    a*  1 
Forest   Service,    this  BU.  booklet    Is   quite    refreshing.      The   olan'-lnu 
effort  and    resulting   text,    I    feel    Is   ge-erally   to   be   commended    fcr 
presenting  a    series  of   choices   and   then  honestly  examining    the   co-Tllctn 
that  each   choice   entails.      Ae-   or»    remembers   the   BLK   of   5   or  6    years 
Is   clear  you   folks  have   come  a    lo"«  way. 

Since   the   final   SIS  will   be   the   basis    ror  dec'sln^o   we   will 
live    with    fcr   ten    Important   years,    a    careful    -1 1  sous-  lor    of   the    facts 
and    full    economic    ;onsequences    of  cur  decision    Is    -eccessarv.      Whatever 
qua:  Draft   EIS  "s°   there   are  als-    several    important 

flaws  *.    Is   oerfect,    hcwever   the  I    =  =  0 

are    sr    fundamental   the  average    citlze'    sould    be   misled    eas! 


This  document  displays   a   thorough    grasp  of  the  lustry 

economy  a-d   the    standard    Justifications   of  that   ecoroi  «'■ 

economies  of    the  forest  other   than   logging   are   i"°s»r'^    the    ~'r  — 
becomes   vague   a  d    the  ha-dllna   clumsy.      Notice    the    of1    me    - 
Alturratlves    1,2,3,4,    i   5.      These  are    rea  =  ';»«   of 

subtly   and    variation  the  timber   management    eH    of   * 

The    remalnl    g    three   alturn-i t' ves   are    cruno    lump!)    tn«t    are   dlff! 
to  divide    Into   their   finer   points    that    they    might    be 

of   the   first   five.      While  all    oc"!fllctl    g    Points   are   wrltte'   down,    fie 
overwhelmli.g   bias   Is   to   Increase   the   allowable   cut.      Thl  =    Is 
surprising,    It    Is  also  displayed   cor.slstantly ,    asal--   and    ao-al-    throutrhnut 
this  documert. 

Basically   this   EIS   plays   off   the  money   to   be   made   clear 
cutting   against  the   birds  and    the  bees   a'd   the    f '  sh  .      As    the   "A 
Oregon  continues   to   emphasise   the   tourist   attractions  of  this   area   the 
monltary  values  of   clear  water,    "^od    fishing   a>-d    prist'  »e  vl=tas  will 

I  be    Increasing,    Indeed    such    thloos   are   orlceles=.      Yet    ir   this  Draft   EI? 
■ 
tourism   a-d    the    fisheries   are   grossly   underestimated.      Th- 

33_2|Umpqua  River   Is   not   rated    asVClas?    I    scenic   area    for  exarrnle. 

II  ;-    1    far  more    sophisticated   analysis  of   * 

resources  and    their   sccncmlc   value,      'iuch   a-  analysis   mlo-ht    'hew   the 
short   term  benefits  of  clearcuttlng  are  wiped   out  by   the    lor»   term 
value   of  old   growth,    the    non-timber  multiple   uses  and    the   co't   of 
loss  of   productivity  due   to   erosion. 

Another   fundamental   shortcoming   of   this  document    Is    the 
assumption  that   "Timber  harvest   under  all   alturratlves  would   be 
accomplished   predominately  by  clearcutt 1 ng . " 


33-4 


33-5 


-3- 

Few  citizens   object   to   the    removal   of   trees,    but   cleareutti  "<,  will 
be   3    -"  '  il  lie's    rury.       I  ,,}■■ 

wasteful    It  the   public's   eye.      Ar   economic   a    -i ) 
high    lead   roeathods   of   clearcuttl  ob  versus   cat    loaai"r,    ve- 
logging    lr,    sensitive  areas,    versus    the    logins    or    sual]     n  lvate 

citizens    is   not  only  deficient    ,    It    Is   absent.  the 

value   of  old   growth    tln.ber  50  years    fron;    now   as    coir.nared    to    a    ti 
14    Inches    In  dlaneter,    It   might  be  qulfe   foolhardy   to    clearcut   every 

il  -g    now.      If    It    Is  employment  we   seek,    are   altur-at've   timber  euttW 
practices   liable   to   put  more   Deople   to  work?      This   document   cries    for 
a        tter   analysis. 

It   seems    to   me   most   of   the   conflicts   of    timber   land    u°*   occur 
on   the    same   crou-d.      Th=    tourlts    like    the    "ce-ery   of   the    water,  which 
1     where   the   fish   live   ana   where   the   riparian   zo-ee   9re    r-u--1   a*  well 
as    sensitive  habitat.      If  meathods   tcjextract    logs    from    such    ar-eas 
without    substantially   altering    the    forest    could    te    contracted    «rti- 
everyone   cculd    be   accomadated. 
|  This    brings  ire   to   a    final    point.      I   would    like   to    see    the 

33-6|alturr!atlves  mapned   out   better.    If   they  each   have    different   acreaa 

|l   wculd    like    to    see   what    1 --    grig   wl  re   are   the   various   protected 

areas   and   where    Is    the  habitat   to   be   protected    by   the  differ' -b      choices? 

The   E1K    needs   to    realize   that    in  ad-ntlor    I         rcvldlne    l0s= 
for  the  mills   they   are   also  adjacert  s   for  a    lot    of   us   a-d   aor* 

are   coming.      .Vhlle    I   do    not    want    tc    see    local    mills    shut,    flow"   thi«    1° 
no  excuse   to   destroy  America's    legacy   of    natural    beauty. 
For  the    shade   of  a    tree. 


Richard    Chasm 


111 


Response  to  comments  in  Letter  33 

33-1         Estimates  of  sport  angl  nt  for  the  Umpqua 

Basin  were  provided  by  the  (Oregon  Dept.  of  Fish  1977 

and  Hassleman  1979).  Estimates  of  recreational   use  of  public  lands 
administered  by  the  Roseburg  District  resulted  from  periodic 
at  both  developed  and  undeveloped  sites. 

33-2         The  North  Umpqua  River,   although  very  high   in  sc  .    arxj  a 

designated  state  of  Oregon  Scenic  Area,  does  not  fit  the  critei 
Class  I  scenery.   It   is  categorized  Class  II    (refer  to  DEIS, 
for  description  of  classes). 

33-3         The  economic  effects  of  BLM-supplied  fishing,   hunting  and  outdoor 
recreation  on  local  employment,  personal   earnings  and  public  1 
are  evaluated  in  Chapters  2  and  3  of  the  EIS.  The  economic  analysis 
is  limited  to  these  resource  uses  because  they  are  the  only  uses  for 
which  reliable  and  regularly  tabulated  data  exist. 

33-4         See  response  to  comment  5-1. 

33-5        The  economics  of  specific  logging  practices  are  considered  in  the 
design  of  each  timber  sale. 

33-6         M^>s  are  available  for  review  at  the  Roseburg  District  Office  for 
those  alternatives  derived  through  the  land  use  planning  process 
(Alts.   3,   4,   6,  8)  as  well  as  the  new  Preferred  Alternative   (Alt. 
9). 


43 


UMPQUA  COMMUNITY  COLLEGE 

THE  COMMUNITY  COLLEGE  OF  DOUGLAS  COUNTY 


IS    "BUD"  HAKANSON 
President 


Posl  Office  Box  967 
Roseburg,  Oregon  97470  0226 
Telephone  440  4600 


August  16,  1982 


District  Manager 

BLM 

777  NW  Garden  Valley  Blvd 

Roseburg,  OR   97470 

Dear  Sir: 

s  recently  come  to  my  attention  that  you  are  proposing 
to  adopt  a  plan  which  would  require  a  number  of  acres  of 
timber  land  to  be  immediately  set  aside  to  protect  Spotted 
Owls.   As  I  understand  it,  the  Alternate  2  Plan  would  still 
aside  150,218  acres  of  old  growth  timberland. 

I:  loss  to  understand  why  that  would  not  suffice 
c)5  pairs  of  owls  in  our  district.   If  you 
divide  150,218  acres  by  55  pairs  of  owls,  you 
2,731  acres  per  pair.   If  in  fact  that  figure  is  cor. 
I  would  recommend  that  you  adopt  Alternate  2. 

This  recommendation  is  made  in  light  of  our  current 
economy,  and  the  fact  that  it  is  subject  to  review  later 

■  . 

We  need  to  get  Douglas  County  back  on  the  road  to  economic 
recovery,  and  at  the  same  time  preserve  the  Spotted  Owls! 

Sincerely, 


I.  S.  Hakanson 


Response  to  comments   in  Letter  43 

43-1         Alternative  2  would  not  set  aside  any  old  growth  timber  land  with  the 
exception  of  that   for  bald  eagles  and  what  may  occur  on  non-commer- 
cial   forest  lands.  There  would,  however,  be  ^proximately  150,000 
acres  of  mature  and  old  growth  forest  remaining  after  one  decade  if 
Alternative  2  were  selected  and   implemented,  but  the  siz^  and 
distribution  of  owl   habitat  may  be  comprcmised  by  unconstrained 
timber  management  activities  to  the  point  where  some  habitat  would  no 
longer  support  spotted  owls. 


President 


ISH  3 


SUN  STUDS,  INC.     SUN  VENEER  DIV. 


44 


August  17,  1982 


Mr.  James  Hart,  District  Manager 

Roseburg  District 

Bureau  of  Land  Management 

777  N.W.  Garden  Valley  Blvd. 

Roseburg,  Oregon      974  70 

Dear  Jim: 

This  letter  is  in  response  to  your  request  for  comments  con- 
cerning the  D.E.I.S.  for  the  Roseburg  District  Land  Use  and 
Timber  Management  Plan. 

Our  general  reaction  to  the  Preferred  Alternative  is  mixed. 
We  are  pleased  to  see  a  proposed  increase  in  the  allowable  cut 
for  the  decade.   We  are  concerned  however  at  how  this  increase 
was  justified.   Most  importantly  we  are  disturbed  at  the  very 
significant  withdrawals  from  the  commercial  timber  land  base 
for  the  highly  questionable  purpose  of  dedicating  old  growth 
timber  to  spotted  owls  who  may  or  may  not  need  it.   Further 
we  are  concerned  about  directing  substantial  management  efforts 
toward  this  species  when  it  is  questionable  as  to  what  it's 
biological  needs  are  and  secondly  whether  or  not  the  species 
really  needs  special  protection  in  the  first  place.   Because 
of  these  concerns  which  we  feel  are  inadequately  addressed 
in  the  D.E.I.S.  we  cannot  support  the  proposed  action. 

One  of  the  common  inadequacies  we  have  found  in  practically 
all  environmental  impact  statements  is  a  tunnel  vision  con- 
centration on  the  impacts  of  forest  management  as  they  relate 
to  the  forest  environment  devoid  of  human  influence.  While 
this  approach  certainly  caters  to  the  views  of  the  preserva- 
tionist camp,  it  does  not  address  the  concerns  and  needs  of 
our  community  and  our  country. 

I  This  D.E.I.S.  does  address  the  concerns  of  the  community  to 
some  extent.  It  does  not  however  address  in  real  terms  the 
trade  off  of  jobs  and  community  stability  versus  preserving 
old  growth  timber  for  a  population  of  owls. 

We  are  quickly  learning  in  today's  economy  that  our  Nation 
has  drifted  too  far  away  from  the  efficient  production  of 
basic  goods  and  services  that  are  necessary  for  human  survival 
and  betterment.   Do  you  think  for  example  that  the  unemployed, 
the  poor  people  and  the  underfed  people  of  this  country  and 
the  world  really  are  that  concerned  about  spotted  owls? 


Mr.  J a me ■ 
August  17,  1982 
Page  Two 

Our  specific  comments  related  to  the  D.E.I.S.  fol  j 

Environmental  Consequences  pages  4-6 

The  author  of  this  section  obviously 

proposed  action  as  black  as  pot.  ,ts  such  as 

"changes  in  plant  communities  and  habitat  could 

some  plant  species"  and  "there  would  be  significant  long-' 

adverse  impacts  to  some  animal  population  certainly 

I  designed  to  alarm  the  reader.   Since  this  plan  only  covers  a 
ten  year  planning  period  it  would  appear  that  these  inflammatory 
statements  are  out  of  line. 

Criteria  for  Evaluating  Alternatives  page  14 

It  would  appear  that  some  of  the  criteria  identified  are 
certainly  more  important  to  the  selection  of  the  preferred 
alternative  than  are  others.   Surely  providing  local  economic 
stability  must  weigh  more  heavily  in  the  decision  making  process 

I  than  for  example  providing  for  Research  Natural  Areas.   I  believe 
a  grouping  of  these  criteria  by  relative  importance  would 
provide  a  better  idea  to  the  public  as  to  how  a  proposed  action 
is  chosen.   It  might  even  help  the  decision  maker. 

Comparison  of  Impacts  page  23 

In  one  short  sentence  on  this  page  you  have  identified,  probably 
by  accident  the  key  concerns  of  this  Impact  Statement.   It 
reads  "Two  areas  of  major  impacts  are  wildlife  habitat  and 
economic  conditions".   My  first  reaction  is  which  is  the  most 
important,  economics  or  wildlife  habitat?   Since  the  proposed 
action  raised  the  land  allocation  for  wildlife  habitat  and 
lowered  the  land  allocation  for  timber  management  it  is  obvious 
that  the  concern  for  wildlife  habitat  was  the  greatest.   I  do 
not  agree  with  this  assessment,  and  neither  do  the  vast  majority 
of  people  who  work  for  a  living  in  this  county. 

Environmental  Consequences  page  63-89 

(A)  Introduction 

The  concluding  statement  reads  "A  basic  assumption  of  the 
analysis  is  that  sufficient  funding  and  personnel  will  be 
available  for  implementation  of  the  final  decision."   For 
the  sake  of  our  economic  well  being  we  sincerely  hope  this 
assumption  is  valid.   Judging  by  the  experience  of  the 
Medford  District  and  their  newly  adopted  Timber  Management 
Plan  it  is  clearly  a  "high  risk"  that  indeed  funding  won't 
be  available  and  our  proposed  allowable  cut  will  fall  as 
monies  for  intensive  management  do  not  appear.   Perhaps 
this  gamble  should  be  discussed  in  the  section  justifying 
increased  allocation  of  land  to  wildlife  habitat. 


Mr.  James  Hart 
August  17,  1982 
Page  Three 

(B)  Threatened  or  Endangered  Plants  page  71 

The  concluding  statement  reads  "Therefore,  environmental 
analysis  accomplished  prior  to  any  site  specific  action, 
would  identify  any  threatened  or  endangered  plant  species 
known  to  be  present  on  the  site  and  appropriate  measures 
to  be  taken."   If  this  process  is  properly  followed  it  is 
difficult  to  understand  how  "changes  in  plant  communities 
44_4  ^nd  habitat  could  eliminate  some  plants."   {page  5)  (Emphasis 
added) .   Thus  the  elimination  of  some  plants  is  not  possible 
or  likely. 

(C)  Impacts  on  Animals  Terrestrial  Vertebrates  page  72 

"Lyon  (1979)  and  Perry  and  Overly  (1977)  have  shown  that 
elk  use  is  reduced  within  one-half  mile  of  roads  traversing 
elk  habitat."   I  would  suggest  that  you  make  these  studies 
available  for  reading  by  the  elk  who  frequently  inhabit 
the  old  Hinsdale  Ranch  pastureland  adjacent  to  Hwy.  38 
just  east  of  Reedsport.   These  elk  obviously  do  not  know 
that  their  behavior  is  nonconforming  to  current  standards 
set  by  Wildlife  Biologists. 

(D)  Threatened  and  Endangered  Animals  page  78-80 

In  the  final  paragraph  under  Conclusions  it  reads  in  part 
"The  cumulative  effects  on  the  northern  spotted  owl  are 
difficult  to  predict  as  planning  efforts,...,  are  just 
beginning."   "However,  if  other  agencies  and  BLM  Districts 
do  not  provide  for  the  recommended  number  then  the  species 
would  certainly  be  in  danger  and  be  considered  for  Federal 
status  regardless  of  the  Roseburg  decision."   (Emphasis 
added) . 


Mr.  James  Hart 
August  17,  1982 
Page  Four 

We  recommend  a  complete  rewriting  be  undertaken  with  the  goal 
of  eliminating  the  bias  against  timber  management  injected 
by  wildlife  worshippers.   The  only  viable  alternative  in  our 
view  is  Alternative  #2  which  should  be  identified  as  the 
proposed  action  in  the  Final  Environmental  Impact  Statement. 

Sincerely, 

SUN  STUDS,  INC. 


Vice  Preside: 
RER:vf 
cc :   Douglas  County  Commissioners 


44-5 


We  find  this  conclusion  to  be  an  incredible  statement.   In 
the  first  place  if  you  cannot  predict  the  cumulative  effects 
on  owl  populations  how  can  you  say  that  the  "species  would 
certainly  be  in  danger" ?   Secondly  this  plan  only  covers 
a  10  year  period  at  the  end  of  which  there  will  still  be 
140,000  acres  of  old  growth  habitat  on  the  District.   Surely 
even  the  owls  could  still  survive  on  only  140,000  acres. 

This  entire  section  indicates  a  paranoid  approach  to  wild- 
life management  which  we  feel  is  completely  uncalled  for. 
Nothing  presented  in  this  section  justifies  a  20, 000  acre 
land  allocation  for  the  owls. 


Conclusion  and  Summary 

We  do  not  support  the  proposed  action  chosen  in  the  D.E.I.S. 
Giving  away  a  significant  commercial  timber  land  base  for 
the  questionable  purpose  of   saving  a  bunch  of  owls  whose 
population  dynamics  are  still  up  for  debate  in  our  opinion 
is  a  violation  of  public  trust.   Furthermore  we  feel  the 
proposed  action  is  in  violation  of  the  O&C  Act  of  1937. 


Response  to  comments  in  Letter  44. 


A 


47 
113 


Weyerhaeuser  Company 


44-1         See  response  to  cannon  issue  4. 


P.O.  Box  275 

Springfield.  Oregon    97477 

AC  503  -  746  2511 


August    18,    1982 


44-2  The  discussion  on  short-term  impacts  has  been  expanded  in  the  FEIS, 
Chapter  3.  EIS  procedures  require  an  analysis  which  goes  beyond  the 
10-year  period  to  consider  long-term  impacts. 

44-3         Refer  to  revised  Appendix  A,  O&C  Forest  Resources  Policy. 

44-4         Present  policy  protects  federally  listed,  proposed  and  candidate 

plant  species  but  does  not  provide  protection  for  other  species  that 
may  be  rare  or  rapidly  declining   in  a  single  State  (see  revised 
Appendix  A).  Also,  see  response  to  comment  16-31. 

44-45       See  response  to  common  issue  1  and  comments  11-8  and  43-1. 


Rose burg   Di  stri  ct    Manager 
Bureau  of    Land   Management 
777    N.W.    Garden   Valley   Blvd. 
Roseburg,    Oregon      97470 

RE: 


We  have  reviewed  and  analyzed  the  Roseburg  Timber 
Draft  Environmental  Impact  Statement  (DEIS)  and 
following  comments  for  your  consideration  in  con 
the  final  DEIS. 


47-1 
47-2 
47-3| 


We  support  the 
to  a  few  modi  f 
harvesting  tec 
Utili zing  broa 
where  appropri 
slopes  under  3 
basi cal 1 y  cons 
The  BLM  ref ore 
page  121  do  se 
standards.  We 
harvested  acre 
intensive  fore 
al 1  acres  with 
have  foun 3  i  r 
over  the  rot at 


use  of  managemen 
i cat  ions.  In  Alt 
hnique  and  age ; 
dcast  burning  as 
ate,  and  mechanic 
5%;  as  wel 1  as  th 
istent  with  inten 
stati  on  managemen 
em  to  be  out  of  1 

also  quest  ion  wh 
s  would  be  schedu 
st  management  sys 
in  a  year  of  harv 
useful  to  ha* 
ion  period  of  the 


t  Alt  ernat  I  ve  #4  (PA) 
ernat  i  ve  #4 ,  the  pr i  nc i  pa  1 
he  sit 
a  primary  source , 

1  site  preparation  I imi 
e  reforesta  t  i  on  targi 
si ve  forest  management  methods . 
t  cost  s ,  how*  J  on 

i  ne  with  the  accepted  Li 
y  only  91.77,  ot  the  annual 
led  for  repl.int.ing  sin.  i 
terns  call  for  rev- 
esting.  Lastly,  we 

!:'  splay 

di  strict . 


Alternative  4  provides  for  approximately  18,300  acres  of 

buffers  along  third  order  and  larger  streams  mana 

modified  area  control.   Harvesting  in  this  area  would  amount 

to  an  estimated  67„,  of  which  only  11%  would  be  by 

Harvest  of  stream  buffers  should  be  consistent  with  the  Oregon 

Forest  Practices  Act.   We  do  not  support  alternative  #4  where 

it  requires  buffers  in  excess  of  FPA  regulations. 


Bureau  of  Land  Management 
August  18,  1982 
Page  2 


Bureau  of  Land  Management 
August  18,  1982 
Page  3 


Alternative  4  calls  for  a  43,77 
sive  timber  product  ion  base  (as 
situation).   The  majority  of  th 
wildlife  habitat  management  tec 
reduction  in  the  timber  base, 
other  forest  uses,  requires  the 
"permanent  forest  production" 
It  is  inconsistent  to  restrict 
on  federal  land  subject  to  that 

I  mandate .   We  recommend  that  the 
cost/ bene fit  analysis  of  its  wi 
consider  more  scientific  input 
Endangered  Speci  es  Task  Force  i 
ment . 


9 -acre  reduct  ion  in  the  inten- 
in  contrast  to  the  current 
t  amount  can  be  attributed  to 

hniques.   We  do  not  support  a 

The  O&C  Act,  while  promoting 
BLM  to  manage  its  lands  for 

s  a  primary  responsibi 1 i ty . 

harvest  of  old  growth  t  imber 
legislated  forest  management 
BLM  do  some  type  of 

ldlife  protection  policies  and 

than  si  mply  the  Oregon 

n  terms  of  spotted  owl  manage- 


47-5 


In  addition  to  support  of  a  management  al t ernat  ive ,  we  would 
1  ike  to  comment  briefly  on  a  few  points  of  management  phi los- 
ophy .   On  page  82  of  the  document  we  f ind ,  "most  timber 
management  pract i ces .. .create  visible  contrast  in  the  land- 
scape.  Assessing  contrast  for  proposed  activity  can  indicate 
the  severity  of  impact  and  help  identify  mitigation  measures 
to  reduce  the  contrast  and  meet  VRM  class  objectives  for  an 
area . "   And  1 ater  we  find  "all  publ ic  1 ands  would  be 
managed  in  accordance  with  objectives  to  mitigate  or  in  some 
cases  avoid  impact  of  management  activities  on  scenic  values." 
Nowhere  do  we  find  the  rationale  explaining  why  the  BLM  VRM 
objectives  are  appropriate  or  should  be  met  at  all.   The 
proposal s  for  scenic  area  management  are  apparently  based 
on  t  he  as sump t  ion  that  only  the  old  growth  stand  is  aesthet- 
LcalLy  pi  easing.   In  an  area  where  timber  is  grown  as  a  crop, 
serving  as  a  basis  for  our  1 ivel lhood ,  we  believe  there  is  a 
need  to  redefine  what  is  scenic .   The  broad  mosaic  of  t  imber- 
1  and  ages  from  old  growth  to  second  growth  to  fresh  clear  cut 
should  be  viewed  as  natural  and  scenic .   The  current  proposal s 
for  visual  resource  protection  subjugate  forest  management 
activity  to  a  visual  quality  criterion  which  is  loosely 
defined  and  not  consistent  with  the  mandate  of  the  O&C  Act. 

In  regard  to  wildlife  habitat  management,  throughout  the 
document  are  found  such  statements  as  the  following: 

Page  79:  'This  long-term  simplification  (of  stand  struc- 
ture) and  loss  of  diversity  would  be  significant 
and  adverse." 

Page  79:   (Snag  dependent  wildlife),  "Alternatives  6  and  7 

would  support  marginal  populations  while  alterna- 
tive 8  would  provide  for  adequate  numbers . " 


Page  75:   "...and  8  snag  dwelling  species  would  decline  to 
bel ow  BLM  target  1  eve Is  in  the  1 ong  term. " 

Page  73:   "A  situation  exists  as  it  is  assumed  that 

habitats  are  currently  at  caring  ca pa city." 

Page  72 :   "Once  roads  are  closed  to  use,  elk  use  incn 
to  near  normal  level s . " 

Page  44:   "Riparian  zones  are  extremely  important  habitat 
because  they  are  used  to  a  greater  extent  bv  a 
greater  variety  of  species  than  any  other 
habi  tat ." 

Page  44 :   "01 d  growth  forest  s  provide  opt  i mum  h 
a  variety  of  animal  spec i > 


47-6 
47-71 


These  statements  imply  a  number  of  things 
is  a  definite  set  of  standards  the  BLM  has  e 
del ineate  good  and  bad  levels  of  habitat  mai 
of  the  statements  made  above,  however,  have 
the  DEIS  by  actual  direct  documentation  and, 
misleading.   Secondly,  the  inference  f1 
the  envi  ronment  is  i  nherent ly  bad ,  is  a  bad 
example ,  when  a  field  of  weeds  i  s  t urned  i  nt 
it  is  simplified  but  its  habitat  and  food  va 
increased .   Last  1 y,  most  forest  management  a 
compati  ble  and  beneficial  to  most  wildlife  s 
exceptions  are  an  important  issue  but  should 
bel  ' e  economic  and  forest  management  consi d 


First,  that  there 
-tied  ,  whi  ch 
ntenati 

ipported  i  n 

there  t 

m  p  1  i  1  i  ■ 

as sump t ion.   For 

e 1 d  of  corn, 
definitely 

The 
t  be  placed 

•ns . 


The  DEIS  recommends  a  cultural  resource  inventory  on  all  acres 
involved  in  ground-disturbing  activities.   We  do  not  support 
this  act  i  on.   federal  law  requires  I  ■  onl y 

i  n  areas  likely  to  con tain  a  significant  cul tui  r  that 

Lvities  cease  when  such  a  site  is  discovered.   To  require 
surveys  on  all  lands  is  a  very  ex pens  i  ve  and  Inef fecti ve 

Is  of  preserving  cul tural  resources .   In  any  case,  the 
cost  of  those  surveys  shoul d  be  borne  by  the  BLM  and  not  its 
licensees  or  contractors. 

The  O&C  Act  places  forest  production  in  the  dominant 

wi  thin  the  scheme  of  the  Bureau*  s  management  of  the  O&C  1 ands . 

Further,  it  is  agreed  that  the  act  does  not  mandate  exclusive 

use  but  instead  requires  management  for  other  intei 

wel 1  as  t  imber  suppl y .   The  Inclusion  of  management 

for  visual  resources ,  exel us ive  wi 1 dl i  f e  habitats  and  expanded 


||4  Bureau  of  Land  Management 
August  18,  1982 
Page  4 


Response  to  conments  tn  ly 


ripari an  zones ,  we  feel  ,  has  gone  beyond  the  management  need 
for  other  forest  uses  and  begins  to  significant ly  erode  the 
dominant  role  of  timber  production  on  O&C  lands. 


Quincy  ty.  Pow.  > 
Vice  President 
Western  Oregon  Region 


47-1        See  response  to  cannon  issue  5. 

47-2        The  acreage  of   initial  planting  ia  equal  to  harvest  area  less  roaded 
area. 

47-3         Harvest  per  decade  in  cubic  foot  volume  would  be  constant  for  all 
decades  for  all  alternatives  until   regulation  is  reached. 


47-4         See  response  to  common  issue  4. 

47-5         Nowhere  in  the  VTW  system  is  it  said  or  implied  that  only  an  old 

growth  stand  is  esthetically  pleasing.     Also,  see  revised  Appendix  A, 
O&C  Forest  Resources  Policy,   and  response  to  comment  58-2. 

47-6         The  following  references  are  the  basis  for  conclusions  in  the  DEIS 
regarding  each  specific  comment: 

Page  79  (simplification  and  diversity  loss) 

Thonas  (1979)  states  that  although  even-aged  management  will 
produce  a  mix  of  successional   stages  in  the  forest,  the  individual 
stands  have  a  low  vertical  diversity  because  of  the  comparative 
simplicity  of  the  stand  structure. 


Page  79  (snag  dependent  wildlife) 


Page  44  (riparian  zones) 


Thomas  et  al .   (1979)  state  that  the  lower  the  population  level 
managed  for,   the  greater  the  risk  of  excluding  a  species  from  an 
area.  They  continue  by  saying  that  management  below  the  40  percent 
of  potential  population  level  may  be  too  low  to  maintain 
self-sustaining  populations. 


Thomas  et  al .   cite  several   authors  drawing  the  conclusion  that 
wildlife  use  riparian  zones  disproportionately  more  than  any  other 
type  of  habitat. 

Page  44  (old  growth  optimum  habitat) 


Page  75  (snag  dwelling  species  decline) 


Refer  to  citation  of  Franklin  et  al.,  page  44   in  DEIS. 


BLM  wildlife  program  targets  for  cavity  dwelling  species  seek  to 
achieve  maintenance  of  viable  populations  thought  to  be  at  or 
above  the  40  percent  potential   population  level.  The  analysis  was 
based  on  this  premise. 

Page  73  (carrying  capacity) 

The  concept  expressed  is  one  generally  accepted  by  practicing 
wildlife  biologists  and  used  in  this  instance  as  a  baseline  in  the 
absence  of  specific  population  numbers. 

Page  72  (roads  and  elk) 

Harcum  (1975)   found  that  elk  use  following  closure  of  logging 
roads   increased  until    it  about  equaled  that  on  otherwise  similar 
unroaded  areas. 


47-7         The  quantity  and  quality  of  the  food  and  cover  elements  required  by 
forest  wildlife  is  a  direct  result  of  the  condition  and  arrangement 
of  the  forest  vegetation  in  space  and  time.     In  the  long  term,   timber 
management  regimes  which  employ  low  minimum  harvest  ages  (50  years) 
and  other  intensive  management  techniques  will  lead  to  a  forest 
ecosystem  with  a  significantly  lower  wildlife  carrying  capacity.  This 
decrease   is  a  result  of  simplified  vertical    (within  stand)   and 
horizontal    (between  stand)  diversity,  v#iich  is  a  product  of  the  loss 
of  stands  50  years  and  older.  For  species  which  depend  upon  stands  in 
excess  of  50  years  to  meet  their  life  needs,  the  impact  is  both 
adverse  and  significant. 

47-8         Costs  of  cultural   resource  surveys  related  to  the  forest  management 
program  are  borne  by  BUI. 


50 


August  19,  1982 


James  Hart,  District  Manager 
August  19,  1982 
Page  Two 


115 


50-1 


James  Hart,  District  Manager 
777  N.  w.  Garden  Valley  Blvd. 
Roseburg,  Oregon   97470 

Dear  Jim: 

The  purpose  of  this  letter  is  to  comment  on  the  adequacy 
of  the  Roseburg  Timber  Management  Environmental  Impact  State- 
ment (Draft) . 

Review  of  the  Environmental  Impact  Statement  (EIS)  reveals 
serious  deficiencies  in  the  analysis  of  the  Proposed  Action  and 
the  seven  other  alternatives.   Also,  the  employment  of  SIMIX  as 
a  forest  simulation  model  to  determine  allowable  cut  levels  will 
yield  results  that  are  fundamentally  deficient  in  economic  consid- 
erations. 

The  National  Environmental  Policy  Act  requires  that  the  EIS 
examine  costs  and  benefits  of  the  Proposed  Action  and  other 
alternatives .   The  EIS  goes  to  great  lengths  to  identify  the 
impacts  to  all  aspects  of  the  social  and  natural  environment. 
However,  the  actual  costs  implicit  in  the  Propsed  Action  are 
conspicuously  missing.   As  an  example,  the  Proposed  Action  contains 
allocations  of  over  30,000  acres  for  Spotted  Owl  habitat.  Old 
Growth,  and  mature  timber  ecosystem  preservation.   After  many 
somewhat  complicated  calculations ,  one  can  determine  from  the  EIS 
that  the  setting  aside  of  this  productive  forest  land  on  250  year 
rotations  will  cost  the  region  $9.5  million  per  year  in  gross 
revenue  and  earnings  and  287  jobs  per  year.   Why  isn't  this  signi- 
ficant cost  explicitly  stated?   More  importantly,  how  does  the  BLM 
justify  this  foregone  revenue  and  employment?   As  a  public  agency 
charged  with  managing  the  O  &  C  lands  for  the  benefit  of  the  local 
communities,  the  Proposed  Action  appears  incongruent  with  your 
objectives. 

All  of  the  alternatives  presented  in  the  EIS  utilize  SIMIX 
as  a  timber  harvest  simulator.   SIMIX  is  a  most  inappropriate 
model  for  determining  allowable  cut  levels  on  the  Roseburg  District. 
The  vast  majority  of  the  timber  on  the  Roseburg  District  is  over 
mature.   Managing  over  mature  forest  land  under  Sustained  Yield- 
Even  Flow  model  (SIMIX)  is  an  unsuitable  means  of  carrying  out  the 
legislative  intent  of  the  0  &  C  Act  of  1937.   The  principle  of 
Sustained  Yield  should  be  interpreted  as  an  overall  objective; 
to  manage  for  continuous  productive  forest  land.   It  should  not  be 
interpreted  as  a  command  to  manage  the  O  &  C  lands  in  an  inefficient 
and  wasteful  manner.   The  scheduling  of  timber  harvests  under  the 
Sustained  Yield-Even  Plow  model  has  produced  a  history  of  chronic 
unemployment  and  economic  stagnation  in  Western  Oregon's  timber 
dependent  communities.   The  Proposed  Action  will  perpetuate  this 
situation  needlessly. 


ef\  nl      The  utilization  of  SIMIX  fails  to  portray  the  actual  costs 
Ow  ^|and  benefits  of  all  alternatives,  as  required  in  the  EIS  process. 

According  to  the  EIS  (Appendix,  page  127)  "SIMIX  is  not  designed 
to  handle  economic  values  or  costs, 'and  it  does  not  seek  out 
alternative  schedules  or  strategies".   Therefore,  the  Sustained 
Yield  model  (SIMIX)  incorporates  a  zero  interest  rate  into  the 
harvest  scheduling  process.   The  outcome  of  this  blatant  disregard 
of  economic  criteria  is  evident  in  the  forest  simulation  model's 
objectives.   The  purpose  of  SIMIX  is  to  calculate  the  "highest 
sustainable  allowable  cut  for  each  alternative",  with  a  projected 
period  of  400  years  to  "assure  that  the  condition  of  no  planned 
reduction  in  allowable  cut  can  be  met."  Obviously,  with  a  zero 
interest  rate,  the  cost  to  the  local  population  of  a  harvest 
schedule  embodying  a  400  year  even  flow  level  is  insignificant. 
However,  what  is  the  actual  cost  in  real  terms  of  unnecessarily 
delaying  liquidation  of  the  BLM's  over  mature  timber? 

It  is  hoped  that  these  comments  will  lead  to  a  better 
analysis  and  display  of  the  costs  and  benefits  of  each  of  the 
alternatives  and  an  examination  of  harvest  scheduling  options. 

Respectfully, 


.kr- 


K 


Ralph  Saperstein 
1784  N.  W.  Estelle 
Roseburg,  Oregon   97470 


Senator  Bob  Packwood 
Senator  Mark  Hatfield 
Representative  Jim  Weaver 
Robert  Burford 


58 


Response  to  conments  in  Letter  50 


50-1         See  response  to  common  issue  4. 


W LUMBER  CO. 


P.  O.   BOX    108 


ROSEBURG,   OREGON    97470         PHONE    (5031    679-874 


50-2         The  comment  refers  not  so  much  to  SIMIX  as  to  the  policy  on 
non-declining  even-flow  constraint.  SIMIX  does  not: 

-  inherently  handle  costs  and  benefits 

-  incorporate  economic  analysis  or  optimization 

SIMIX  is  generally  recognized  as  a  valid  model  given  an  even-flow 
constraint  (refer  to  DEIS,  Appendix  C,  page  127).  The  allowable  cut 
determination  is  based  on  a  nondeclining  harvest  level  over  time  (See 
OfcC  Forest  Resources  Policy,  Appendix  A). 


August  18,  1982 


Mr .  James  E.  Hart 
Roseburg  District  Manager 
Bureau  of  Land  Managemen  t 
777  NW  Garden  Valley  Blvd. 
Roseburg,  OR   97470 

Dear  Mr.  Hart: 

This  letter  is  in  response  to  your  request  for  input  on  the  draft 
Timber  Management  Environmental  Impact  Statement  lor  the  Roseburg 
sustained  yield  unit. 

Roseburg  Lumber  Co.  is  highly  dependent  upon  the  Ros< 

for  its  timber  supply.   We  operate  plants  at  li\  raphic 

locations  in  Douglas  County,  which  normally  employ  approxin 
people.   These  facilities  all  draw  wood  from  the  Rob<! 

In  that  our  operations  are  extremely  dependent  on  the  federal  govern- 
ment for  thier timber  supply,  any  change  in  the  allowable  cut  ha 
tremendous  impact  on  our  future. 

Roseburg  Lumber  also  has  a  close  historical  relationship  with  tl 
lands,  in  that  the  bulk  of  our  industrial  timbe: 

with  the  BLM  patchwork  ownership.   Because  of  this  situation,  Wi 
very  much  concerned  about  the  land  use  and  silvi cultural  recommend 
contained  in  the  various  alternatives.   Such 


a  direct  and  long  te 
administered. 


Such  programs  will 
impact  on  the  manner  in  which  our  lanci- 


rongly  recommend  the  selection  ol 
is  based  on  the  iol lowing  reasons: 


In  Douglas  County ,  the  wood  products  indus 

provides  jobs  for  more  than  90%  of  the  Coum 

manufacturing  employment .   Becau 

ship  with  si         '  trade  employment,  anj 

in  the  base  wood  industry  employment  has  an  amp 

affect  on  the  whole  company. 

The  flow  of  O  i  C  funds  to  various  local  government 
agencies  is  critical  in  the  maintenance  and  growth 
of  many  key  government  servj 


116 


E.  Hart 


i  18,  1982 


James  E.  Hart 


Augunl  18,  1982 


3.  Under  the  O  k   C         137,  the  ro  nues 
from                                   ,i ion  both 
from  a  congressional  mandate,  and  in  support  of 
local  SOG  i                                  :   ,  ruber 
production  as  the  dominant  use  on  forest  lands 
admin               Bureau  of  Land  Management.   The 
law                        elling,  cutting  and 
regrowing  <>i  timbei               lominant  use  on 

mi  the  objective  of  main- 
ting  a  stable  economic  base  for  local  dependent 
communi  tie 

4.  This  stable  revenue  base  is  certainly  not  the  cs 
today  in  the  local  Douglas  County  economy.   Industry 
and  communities  throughout  the  Douglas  County  area  are 
reeling  as  the  result  ol  the  collapse  of  the  national 
wood  products  market.   Although  this  is  hopefully  a 
short  term  problem,  a  stable  wood  supply  is  critical 
for  any  near  term  recovery. 

5.  Local  industry  is  going  through  a  transition,  both 
in  terms  of  technology  and  wood  supply.   In  the  next 
20  years,  there  will  be  a  supply  gap  between  the  old 
growth  and  second  growth  timber  stands  as  indicated 
Ln  the  Beu  ,  which  was  part  of  the  Forestry 
Program  for  Oregon  (published  in  1977).   During  this 
period,  the  need  for  a  stable  and  re 1 i able  timber 
supply  will  be  greater,  in  that  the  economy  will  be 
quite  f ragi le. 

6.  Although  Alternative  #2  "emphasizes  timber  production", 
this  management  program  more  than  meets  the  standards 
that  have  been  establ ished  by  various  agencies  relative 
to  the  protection  of  the  watershed,  wildlife,  and  other 
environmental  and  multiple  use  resource  values. 

During  the  decade  of  the  1970s,  there  was  a  period  of  experimentation, 
both  in  terms  of  environmental  and  forestry  management  concepts . 
Because  of  the  avai lability  of  the  forest  resource,  the  philosophy 
has  been  to  hold  volume  in  reserve  in  order  to  ensure  that  non-timber 
resources  were  protected.   As  a  result,  the  short  term  economic 
productivity  of  these  lands  was  sacni 

Given  the  present  economic  situation,  the  clear  mandate  contained 
in  the  0  &  C  Act,  and  the  broader  base  of  expertise  that  has  been 
developed  over  the  last  decade,  it  is  now  time  for  these  lands  to 
contribute  their  full  capacity  to  the  needs  of  our  community. 
alternative  02  presents  the  proper  compromise  in  meeting  these  various 
object i \ 


1  . 

58   1 


58-2 


58-3 


We  shai  iti ting 

a  potentially  uni- 
ts a  trade  off  i 
in  thi  i <  st  land  base.   If  the  avail- 

ability of  these  fund 
probable  in 

I  supply  on  an  already  str.i  my  would  be 

catastrophic . 

There  void  in  the  dr;. 

to  the  goal  of  proper  coordination  ob  »ith 

with  other  landowners  and  agencies  (pages  26-27).   There 

is  considerable  discussion  and  analysis  of  management 

techniques  r<  I  directives  and  guld< 

establ lshed  by  federal  and  state  agencies .   But  there 

is  no  consideration  of  the  tremendous  interaction 

between  the  private/industrial  landowner  and  the 

Bureau  of  Land  Management. 

Given  the  patchwork  nature  of  the  0  k   C  land  own* 
the  manner  in  which  these  lands  are  managed  has  a 
significant  impact  on  the  adjacent  landowner.   This 
interaction  ef  f ects  land  use ,  road  access ,  and  general 
forest  management.   Although  the  bulk  of  Roseburg 
Lumber  Co. 's  industrial  forest  lands  intermix  almost 
in  their  entirety  with  the  Bureau  of  Land  Manat 
ownership,  at  no  time  were  we  contacted  relative  to 
the  Impact  of  this  plan  on  our  operations,  or  the 
potential  impact  on  our  management  procedures  on  the 
BLM  ownership. 

This  lack  of  coordination  is  specifically  illustrated 
in  certain  land  use  catagorles.   On  page  83,  there 
is  a  list  of  areas  that  qualify  for  visual  resource 
management  (VRM),  and  designated  with  high  sensitivity 
levels.   In  this  category,  logging  and  forest  manage- 
ment procedures  are  restricted  in  order  to  preserve 
certain  esthetic  values. 


In  viewing  the  plan  from  a  detailed  standpoint, 
the  following  points: 


I  would  like  to  make 


For  example,  one  area 
Reservoir.  When  this 
by  the  County  as  a  wa 
understanding  be1 
the  County .  Existing 
conducted  as  long  as 
Oregon  Forest  Practic 
degradation  to  the  wa 
without  any  prior  con 
or  County  Planning  st 
additional  zoning  ove 
timberland  on  the  0  & 
precedent  for  restric 
of  lands  intermixed  w 


so  designated  is  the  Berry  Creek 
area  was  originally  proposed 
tershed,  there  was  a  very  clear 
small  landowners,  industry  and 
forestry  practices  would  be 
they  were  consistent  with  the 
es  Act,  and  did  not  result  in 
tershed.   Suddenly,  the  BLM, 
sultation  to  adjacent  landowners 
aff,  has  in  affect  proposed  an 
rlay.   In  restricting  commercial 

C,  you  have  also  set  the 
tion  on  the  operational  capaci  ty 
ith  these  holdings.   A  similar 


James  E.  Hart 


August  18,  1982 


rQ   olsituation  is  true  on  at  least  30%  of  the  proposed 
OO  v|areas  contained  on  page  83.   I  would  strongly 
recommend  that  this  superficial  assignment  of 
management  restrictions  on  lands  intermixed  with 
commercial  timberlands  be  reviewed.   Roseburg  Lumber 
would  be  happy  to  provide  detailed  input  in  such 
a  process. 

I  hope,  that  in  developing  the  final  draft  statement,  the  agency 
will  use  common  sense  in  establishing  the  appropriate  balance 
between  various  resource  uses.   In  that  the  economic  problems  of 
the  Douglas  County  area  are  so  obvious  and  so  critical,  the  selection 
of  Alternative  #2    represents  the  one  sound  approach  in  meeting  the 
needs  of  both  the  environment  and  the  community. 

Sincerely , 

ROSEBURG  LUMBER  CO. 


Response  to  comments  in  Letter  58. 

58-1         See  response  to  common  issue  2. 

58-2         Of  the  visual   resource  areas  listed  on  page  83  of  the  DEIS,   forest 

management  activity  restrictions  are  limited  to  BLM  recreation  areas 
and  State  of  Oregon  designated  scenic  areas  (segments  of  North  Umpqua 
Highway  138,  Highway  42,   227  and  Interstate  5)-  Otherwise,  mitigating 
measures  and  project  design  features  as  described   in  the  DEIS 
provide  for  scenic  values  in  such  areas  as  Berry  Creek  Reservoir. 


Allyn   C.    Ford 


58-3         Management  of  intermingled  private  lands  is  controlled  by  State  Laws 
and  local   land  use  plans.  Refer  to  DEIS,  Chapter  1,  pages  27-29. 


BLM's  preferred  land  use  alternative  and  other  alternatives 
considered  in  the  land  use  planning  process  were  reviewed  by  the 
Douglas  County  Planning  Department.  Tne  Preferred  Alternative  is 
believed  to  be  consistent  with  Douglas  County's  Comprehensive  Plan. 
BLM  visual  management  practices  are  not   intended  to  set  any  precedent 
for  the  management  of  intermingled  private  lands.  Also,   see  response 
to  comment  4-4. 


68 


DOUGLAS  TIMBER  OPERATORS 

Suite  222,  Pacific  Building 

Roseburg,  Oregon  97470 


August  18,  1982 


117 

land    to   constrained    timber    production.       Th ; 

Owl    habitat,  old    growth    and    ecosystem    preservation    thai 

on    artificially    long    (250   years)    rotal 

tion   of    the   O  &   C  grant    land  ront    to    th- 

munities    adjacent 


Mr.    James    Hart,    District    Manager 
Bureau   of    Land    Management 
777    NW   Garden   Valley    Blvd. 
Roseburg ,    Oregon    974  70 

Dear    Jim: 

The  following  comments  pertaining  to  the  Roseburg  Timber  Managem-i;' 

Environmental  Impact  Statement  (Draft)  are  submitted  on  be hi 

the  Douglas  Timber  Operators .   As  an  association  representing  local 

t  product  manufacturers,  loggers  and  retailers,  with  subs' 
tial  dependence  on  public  timber  supplies,  our  interest  in  planning 
Cor  the  future  management  of  local  forest  lands  is  acute.   Over 
l ? , 000  workers  in  Douglas ,  Coos  and  Lane  Counties  are  norma  lly  em- 
ployed by  our  members . 

As  we  are  all  aware,  the  nation  is  experiencing  the  severist  reces- 
sion in  decades.   Local  timber  supply  will  have  a  profound  effect  on 
the  forest  industry' s  ability  to  provide  prosperity  and  stability  for 
the  area.   Therefore,  BLM  planning  decisions  can  hold  the  key  to  local 
companies '  likelihood  of  surviving  the  current  recession  and  thriving 
once  the  economy  turns  around . 

The  Proposed  Action,  as  described  in  the  DEIS,  has  some  serious  short 
comings.   The  PA  designates  52,000  acres  of  prime  commercial  timber 


68-1 


In  light  of  the  nev.  >m  the  Washington,  D-C. 

garding  the  selling  aside  of  produi 

timber  uses,  revision  of  the  Proposed  Actioi 

cision  to  remove  52,000  acres  from  the  Intel 

base  was  derived  from  i 

ledge.   In  addition,  in  198J  the  Oregon  State  Lei 

Memorial  No.  1 .   In  this  resolution  thi 

"make  cor  tain  every  possible  effort  is  rr.^it   t_  ^  p.-  ..-.ser  ve  the  in  tens  l  ■■■■:- 

management  land  base  for  timber  production  purposes". 

This  statewide  emphasis  on  preserving  the  land  ba.-^e  1 
•  ■  t   Land  is  not  new.   The  Oregon  Board  of  Forest .i 
state  position  in  its  Fores try  Plan  -or  Oregon.   A  ba 

the  progran  is  "to  maintain  the  maximum  potc; 
base  consistent  with  other  resou- 
quality".   The  Proposed  Act  ion  is  l no 

Consequent  ly ,  reductions  of  the  managed  timber  land  b-i 
conflict  with  policy  and  objectives  from  the  BLM  headqu 
ington,  D.C.,  the  Oregon  State  Legislature,  the  Oregon  Board  o* 
local  governments  and  the  forest  industry  of  Southwestern  Oregon . 


Another  facet  of  the  Proposed  Action  which  deserves  closer  scrutiny 
in  the  decision  process  is  the  heavy  reliance  on  intensive  management 
to  maintain  allowable  harvest  levels.   The  Proposed  Action  will  require 
an  increase  in  funding  of  approximately  42%  to  meet  intensive  manage- 
ment object ives.   While  this  increase  may  be  feasible  for  the  long-run, 
it  is  unlikely  for  the  short -run,  considering  current  reduced  stumpage 
values  and  congressional  unwillingness  to  provide  supplemental  appro- 
priations.  Your  ability  to  carry  out  the  proposed  course  of  action  may 
be  in  serious  jeopardy.   Any  reduction  or  elimination  of  cultural  treat- 
ments will  in  turn  force  a  reduction  in  the  al lowable  harvest.   A  similar 
situation  in  the  Medford  BLM  District,  where  harvests  had  to  be  reduced 
over  20MM,  demonstrates  the  reality  of  our  concern.   The  most  likely 
effect  of  the  Proposed  Action  with  its  reduced  land  base  and  dependence 
on  intensive  management  would  be  to  meet  the  harvest  objectives . 

Alternative  2  offers  a  much  more  viable  and  appropriate  plan  for  managing 
the  Roseburg  District.   Alternative  2  provides  for  over  360,000  acres  in 
the  Intensive  Timber  Production  Base  which  is  over  27, 000  acres  more  than 
the  Proposed  Action.   The  addi  tional  increase  in  annual  sustained  yield 
harvest  of  18  million  board  feet  will  yield  additional  public  revenues 
and  worker  earnings.   In  addi  tion,  Alternative  2  would  produce  over  300 
jobs  more  than  the  Proposed  Action. 

The  benefits  of  Alternative  2  are  achieved  without  sacrificing  non- 
timber  resources  and  uses  on  the  Roseburg  District.   Stream  protection, 
visual  quality  and  wildlife  habitat  is  enhanced  with  an  al location  of 
24,786  acres.   Alternative  2  will  more  than  double  the  area  designated 
for  recreation  with  respect  to  current  conditions.   Most  important ly. 


at  the  end  of  10  years,  over  140,000  acres  of  m«  <  :  will 

still  be  available  for  reclassification.   This  factor  the  op- 

tion to  provide  adequate  protection  for  the  Spotted  Owl  and  old  growth 
ecosystems,  should  continuing  research  deem  permanent  land  alJor  ■ 
necessary . 

In  order  to  provide  scientifically  sound  analys : . 

the  DEIS,  DTO  has  retained  the  services  of  two  independent  con;-  i 

firms.   Dr.  Robert  Vincent  has 

draft.   Ma.con  Bruce  &  Girard,  Inc.  has  reviewed  the  ecom 

in  the  DEIS.   The  results  of  the] 

considered  as  part  of  DTO's  formal  input  t< 

Based  on  our  review  and  the  rep 
that  in  the  BLM  to  conn: 

and  local  objectives  t  he  Proposed  Action  should  bo  aband 
and  Alternative  2  adopted.   The  BLM  will  ha\ 
in  your  efforts  to  appropriately  revise  the  Proposed  Action. 

Si net  : 
DOUG; 


fi^jt^CL^T' 


Lynn  Herbert 
President 


118 


AN  ANALYSIS  AND  DISCUSSION  OF  THE  WILDLIFE-FOREST  ASPECTS 

OF  THE  ROSEBURG  TIMBER  MANAGEMENT  DRAFT 

ENVIRONMENTAL  IMPACT  STATEMENT 


Page 

INTRODUCTION  2 

ALLOCATION  OF  MATURE  AND  OLD-GROWTH  ACRES  FOR  WILDLIFE  ....  k 

ELK  AND  ROAD  SYSTEMS 15 

INTENSIVE  FOREST  MANAGEMENT  AND  WILDLIFE  18 

RIPARIAN  AREA  MANAGEMENT  AND  FISHERIES 23 

CONCLUSIONS 25 

LITERATURE  CITED  27 


prepared  for 
DOUGLAS  TIMBERS  OPERATORS 


Robert  E.  Vincent,  Consultant 
August,  1982 


I   INTRODUCTION 


The  Roseburg  Timber  Management  Draft  Environmental  Impact  Statement  is  a  major 
improvement  over  previously  written  EISs.   Issues  have  been  addressed,  data 
presented,  and  alternatives  analyzed  in  a  comprehensive  manner.  The  Timber 
Production  Base  is  particularly  important  for,  although  BLM  assumes  funding 
will  always  be  available  for  intensive  management,  this  may  not  be  the  situation. 

By  far  the  largest  acreage  in  the  SYUs  is  withdrawn  from  the  intensive  Timber 
Production  Base  for  wildlife  habitat.   A  Constrained  Timber  Production  Base 
through  Modified  Area  Control  harvest  has  merit  over  no  harvest;  nevertheless, 
acres  allocated  for  constrained  production  should  be  examined  carefully  and 
constrained  harvest  applied  sparingly.   This  analysis  focuses  upon  those  wildlife- 
land  allocations  that  most  reduce  the  Intensive  Timber  Production  Base. 

Subject  areas  emphasized  in  this  discussion  are  (1)  old-growth  forests  and 
spotted  owls,  elk,  and  corridors;  (2)  elk  and  road  systems;  (3)  intensive 
forest  management  and  wildlife;  and  (4)  riparian  areas.   Generally,  the  analysis 
shows  that,  for  this  planning  cycle,  allocation  of  old-growth  forest  need 
not  be  carried  out  because  a  more-accurate,  meaningful  allocation  can  be  made 
later  with  greater  information  and  no  Individual  resource  will  decline  to 
any  extent  in  the  meantime.   Also,  literature  and  common  knowledge  strongly 
suggest  that  road  impact  upon  elk  use  of  habitat  may  be  overemphasized.   Broad 
condemnation  of  the  impact  of  intensive  forest  management  on  wildlife  is  not 
justified,  and  the  proposed  riparian  area  management  will  adequately  protect 
and  enhance  the  many  uses  of  streamside  areas. 


hatchery  fish  have  a  role  in  the  fishery,  for  listing  MFP  Withdrawals  by  use, 
and  for  preparing  a  table  of  nonoverlapping  resource  allocation  of  forest 
land. 

One  major  weakness  seems  to  be  conclusion  forming  contrary  to  the  supporting 
and  stated  information. 


The  BLM  is  to  be  commended  for  proposing  the  concept  of  Area  Control  Harvest, 
for  considering  a  250-year-harvest  age  of  riparian  and  wildlife  old-growth 
blocks,  for  managing  the  Tyee  Area  with  special  consideration  for  elk,  for 
realizing  the  possible  wildlife  use  of  non-forest  lands,  for  recognizing  that 
-  2  - 


119 


II  ALLOCATION  OF  MATURE  AND  OLD-GROWTH  ACRES  FOR  WILDLIFE 


The  Roseburg  BLM  Sustained  Yield  Units  (SYUs)  contain  approximately  423,896 
acres  in  total.   As  an  example  of  how  the  intensive  forest  management  base 
is  computed,  Alternative  2  and  Alternative  4  (Proposed  Action)  are  examined. 
Land  allocated  for  Planned  Timber  Harvest  under  Alternatives  2  and  4  is  reached 
by  designating  acres  for  either  no  harvest  or  for  constrained  harvest. 


Acreage  Allocation 


Alternative  2   Alternative  4 


Total  Acres 

No  Planned  Timber  Harvest 

Physical  Land  Characteristi 
MFP  Withdrawals 
Planned  Timber  Harvest 
Constrained  Base 
VRM 

Wildlife 
Intensive  Base 


423,896 

423,896 

38,530 

38,530 

32,530 

32,826 

5,704 

5,704 

385,366 

385,366 

24,786 

52,047 

3,682 

2,646 

21,104 

49,401 

360,580 

333,319 

Thus,  the  difference  of  27,261  acres  between  the  Intensive  Base  Alternative  2 
and  the  Proposed  Action  is  the  acreage  allocated  for  spotted  owls,  old-growth 
blocks,  and  80-acre  blocks,  in  other  words,  the  acreage  of  mature  and  old- 
growth  forest  for  spotted  owls  and  for  old-growth  corridors.   VRM,  bald  eagle, 
osprey,  raptor,  and  riparian  acreage  allotments  are  all  the  same  between  the 
two  alternatives. 

These  constrained  harvest  acres  of  old-growth  forest  for  wildlife,  even  with 
limited  harvest  under  Modified  Area  Control,  remove  18  MM  bd.  ft.  from  the 
annual  timber  harvest.   Therefore,  these  27,000  acres  that  grow  18  MM  bd. 
ft.  are  significant  and  worthy  of  evaluation  as  to  why  they  are  placed  in 
the  Constrained  Harvest  Base.   To  illustrate  the  comparative  magnitude  of 
impact  of  18  MM  bd.  ft.  on  local  employment  and  earnings  in  Douglas  County, 


18  MM  bd.  ft. 
Timber  Harvest 

All  Other 
Resource  Occupations 

232 
$  3,072,600 

99 
$  567,000 

note  the  following: 


Persons  Employed 

Personal  Income 

Three  wildlife  resource  allocations  comprise  nearly  all  of  the  Constrained 

Base:   (1)  spotted  owl  habitat,  (2)  old-growth  blocks  that  are  overlapping 

or  joint-use  for  all  except  1,757  acres,  and  (3)  80-acre  blocks  that  are  nearly 

all  single-use  designation  (9,415  acres,  single-use;  1,167,  overlapping-use) . 

A.   Existing  Situation 

In  contrast  to  some  BLM  Districts,  the  Roseburg  District  has  large  acreage 
in  mature  and  in  old-growth  stands.   Also,  the  District  has  a  comparatively 
large  spotted  owl  population.   High  amounts  of  these  three  permit  flexibility 
in  the  planning  process. 

1.  Mature  Forest.   The  SYUs  contain  79,800  acres  (202)  in  the  116-to- 
195-year-habitat  age  class,  while  all  lands  contain  121,500  acres  (92)  of 
mature  forest. 

2.  Old-Growth  Forest.   The  SYUs  contain  110,900  acres  (27%)  in  the  196+ 
-year-habitat  age  class,  while  all  lands  contain  234,100  acres  (162)  of  old- 
growth  forest.   Accordingly,  mature  and  old-growth  forest  are  not  a  scarce 
habitat-age  class  but  total  190,700  acres  or  47%  of  the  Roseburg  District. 

3.  Spotted  Owl  Populations.   Current  census  effort  has  found  55  habitat 
units  that  each  support  a  pair  of  owls,  plus  found  30  additional  locations 

in  the  SYUs  where  spotted  owls  have  been  found  occasionally.   In  addition, 
63  pair  of  owls  have  been  recorded  on  other  ownership  within  the  planning 
area.   A  total  of  148  pair  of  spotted  owls  are  known  thus  far  to  occupy  habitat 
within  the  EIS  area.   Of  the  known  55  habitat  units  in  the  SYUs,  only  4  were 
estimated  to  be  in  poor  (less  than  150  acres  old  growth)  condition.   Sixteen 
of  the  occupied  habitat  units  have  less  than  300  acres  of  old-growth  forest. 
Hence,  30%  of  the  known  locations  supporting  a  pair  of  spotted  owls  in  the 
SYUs  are  doing  so  in  a  habitat  unit  smaller  than  300  acres  of  old-growth  forest. 


68-2 


The  permanency  of  spotted  owls  in  small  habitat  units  is  unknown,  but  they 
are  there  and  they  have  been  counted  with  regularity. 

B.   Old-Growth  Forest  and  Spotted  Owl 

Present  status  of  the  spotted  owl  population  would  have  to  be  considered  good 

in  the  SYUs.   The  Proposed  Action  is  to  protect  habitat  fully  for  18  pair 

of  owls,  habitat  that  consists  of  a  300-acre,  old-growth  core  plus  an  additional 

900  acres  with  at  least  one-half  older  than  30  years.   Through  the  10th  decade, 

this  action  would  maintain  the  prescribed  pairs  of  owls.   The  relationship 

between  spotted  owls  and  acres  of  old-growth  forest  is  unclear.   According 

to  Table  1-5  (DEIS),  if  1,000  acres  were  a  minimum-habitat  requirement,  the 

spotted  owl  would  not  exist  to  the  10th  decade  under  Alternatives  3  and  4, 

notwithstanding  that  31,800  of  old-growth  forest  would  be  extant.   Under  Alternative 

7,  no  owls  would  exist  by  the  10th  decade  even  with  70,000  acres  of  old-growth 

forest,  whereas  under  Alternative  6  with  68,100  acres,  24  pair  would  be  maintained. 

These  relationships  are  inconsistent. 


68  3 


No  pro ject 1 


are  given  for  spotted  owl  populations  at  the  end  of  the  first 


decade  so  extrapolation  must  be  done  from  the  acres  of  old-growth  habitat. 
The  existing  condition  has  a  known  habitat  unit  for  each  2J300  acres  of  potential 
habitat.   Consequently,  at  the  end  of  the  first  decade,  all  alternatives  except 
5  could  be  expected  to  maintain  a  minumum  of  approximately  35  pair. 

Data  on  habitat  requirements  of  spotted  owl  are  limited  and  incomplete.   Current 
available  data  are  solely  from  the  research  of  one  individual.   Confusion 
also  exists  between  the  original  Oregon  Endangered  Species  Task  Force  management 
recommendations  and  the  proposed  revision  of  the  Oregon  Interagency  Spotted 
Owl  Management  Plan.   Although  the  latter  is  only  a  proposal,  not  an  accepted 
or  adopted  revision,  even  as  a  proposal  the  revision  was  to  maintain  the  option 
of  the  additional  acreage  of  old-growth  forests  for  a  5-year  period  only. 
68_4|'Yet»  this  unadopted  proposal  is  repeated  and  used  several  times  in  the  DEIS. 

Lack  of  data  become  awkward  for  the  authors  of  the  DEIS  for  it  appears  necessary 
to  inject  frequent  "weasel"  words  because  definitive  data  are  absent.  A  manage- 
ment decision  that  impacts  millions  of  board  feet  of  timber  harvest  annually. 


68  5 


needs  to  be  based  on  facts,  not  supposition.   Phrases  and  words  as  "these 
may  be  .  .  ."(p. 47),  "in  the  opinion  of  the  BLM  district  biologist  .  .  ."(p. 47), 
"applying  extremely  rough  projections  .  .  ."(p. 72),  "assuming  that  these  recommendations 
.  .  ."(p. 78),  "based  on  the  assumption  that  .  .  ."(p. 79),  "assuming,"  "indicates," 
"may  be"  (p. 80),  and  "the  cumulative  effects  on  the  northern  spotted  owl  are 
difficult  to  predict  as  planning  efforts  by  land  management  agencies  are  just 
beginning  .  .  ."(p. 80)  express  indecision.   In  addition,  "no  action  would 
be  taken  until  habitat  management  plans  are  completed  .  .  ."(p. 79)  obviously 
show  habitat  management  plans  have  not  been  formulated  for  wildlife  areas. 

Given  the  necessity  of  using  these  many  indefinite  words,  given  the  statement 
that  cumulative  impacts  on  the  owl  are  difficult  to  assess,  and  given  the 
absence  of  wildlife-habitat  management  plans,  the  logical  conclusion  is  that 
BLM  needs  additional  planning  time  so  that  a  decision  of  this  magnitude  is 
not  being  based  on  guesses  and  assumptions. 

The  same  indefinite  phraseology  is  used  to  disguise  lack  of  hard  data  on  older 
forest  habitat:   "the  functioning  of  the  old  growth  forest  as  a  system,  however, 
has  not  yet  been  studied  in  depth  .  .  ."(p. 42),  and  "there  Is  no  definitive 
description  of  the  functioning  of  the  old  growth  system  and  its  importance 
to  long-range  timber  production"(p. 71) .   Again,  the  need  to  guess  is  shown 
by  "habitat  structure  for  all  lands  .  .  .  cannot  be  accurately  calculated"(p.44) . 
Confusion  of  the  role  and  amount  of  old-growth  forests  is  further  compounded 
by  the  sentence  on  p.  71,  "All  alternatives  except  Alternatives  1,  2  and  5 
would  provide  an  adequate  representation  of  the  original  old  growth  systems." 
Yet  after  10  years,  the  timeframe  of  this  Timber  Management  Plan,  there  is 
a  IX  difference  in  the  acres  of  old-growth  forest  under  Alternative  2  and 
Alternative  3.   In  this  situation  where  admittedly  the  function  and  importance 
of  old-growth  systems  are  not  well  known  nor  the  amount  accurately  calculated, 
it  is  inconceivable  that  precise  prediction  could  be  made  that  Alternative 
2  would  not  provide  adequate  representation  while  Alternative  3  with  only 
IX   more  old-growth  habitat  would  provide  adequate  representation. 

Replacement  of  younger  forest  with  older  forest  is  a  basic  premise  of  BLM 
planning  as  shown  by  Alternative  8,  80-acre  blocks  of  mature  timber,  the  corridor 


120 


Led  Area  Control.   Or  BLM  cannot  squ. 

the  concept  In  their  own  thinking  that  old-growth  forest  is  irreplaceable. 
Irretrievably  lost  does  not  app  I  rowth  forest.   Thifl  latter  concept 

is  expressed  tacitly  by  "old  growth  habitat  that  would  be  irretrievably  lost 
as  long  as  those  acres  are  managed  im  timber  production  .  .  ."(p. 72). 

Certainly  the  implied  idea  is  that  whenever  intensive  timber  management  vera 
stopped,  old-growth  habitat  would  not  be  irretrievably  lost  but  would  be  reformed 
as  a  natural  consequence  of  succession  and  community  development  as  expressed 
on  p.  hi   and  p.  44.   Moreover,  if  as  assumed  by  BLM  (p. 73)  that  habitats  are 
currently  at  carrying  capacity,  these  new  old-growth  stands  will  support  populations 
of  those  species  that  prefer  old-growth  forests. 

Thus  to  sum  up,  the  best  planning  action  for  the  spotted  owl  may  well  be  to 
take  no  action  during  this  planning  period  for  the  following  reasons: 

(1)  At  the  end  of  the  planning  period  covered  by  this  DEIS,  over  70,000 
acres  of  old-growth  forest  will  remain  in  the  SYUs  under  all  alternatives 
except  Alternative  5. 

(2)  Spotted  owl  numbers  are  comparatively  high. 

(3)  Confusion  exists  over  minimum  habitat  requirements  of  spotted  owls. 

(4)  The  relationship  between  owl  habitat  and  older  forest  is  unclear. 

(5)  At  the  end  of  the  planning  period  an  adequate  number  of  owls  will 
remain  even  without  special  allocation  at  this  time. 

(6)  Lack  of  data  on  owls  and  their  habitat  necessitates  the  frequent 
use  of  non-specific  phrases. 

(7)  Habitat  management  plans  have  not  been  completed  for  SOMAs. 

(8)  The  function  and  role  of  the  old-growth  system  is  unknown. 

(9)  Old-growth  forest  is  replaceable  and  is  a  renewable  resource 

The  spotted  owl  was  classified  as  threatened  by  the  then  Oregon  Department 
of  Wildlife  on  January  10,  1975,  and  no  species  have  been  added  to  or  removed 
from  this  classification  since  that  date.   At  this  time,  other  states  and 
provinces  have  not  given  the  spotted  owl  special  designation.   British  Columbia, 
Washington,  or  California  do  not  have  specific  management  considerations  for 
the  spotted  owl,  and  owls  have  the  same  legal  status  and  protection  as  all 
other  native  nongame  birds  in  these  three  states.   The  owl  is  not  listed  nor 


I 


has  it  been  proposed  for  listing  under  the  Federal  Endangered  Species  Act. 
"The  species  (spotted  owl)  situation  does  not  meet  the  Endangered  Species 
Act  of  1973  definitions  of  either  Threatened  or  Endangered" (U. S .  Fish  and 
Wildlife  Service  1982  p. 24). 

C.   Old-Growth  Forest  and  Elk 

Elk  are  unevenly  distributed  throughout  the  SYUs  with  a  concentration  in  the 
Tyee  Area  of  the  Drain  Unit.   The  elk  population  of  660  provides  an  average 
annual  harvest  on  BLM  land  of  54  elk  and  an  annual  expenditure  of  2,738  hunter 
days  (Roseburg  District  PAA) .   Over  one-half  of  the  harvest  is  from  the  Drain 
Resource  Area.   As  a  result,  elk  hunting  la  a  minor  resource  use  in  the  SYUs 
and  needs  to  be  viewed  in  prospective  with  dollars  and  people  involved  in 
other  resource  uses. 

The  relationship  between  elk  and  old-growth  forest  is  unclear  and  ill-defined. 

If  available,  elk  may  well  use  old-growth  stands;  on  the  other  hand,  the  requirement 

of  old-growth  forests  for  elk  survival  is  probably  mainly  a  "smoke-screen." 

To  many,  common  knowledge  examples  exist  of  elk  herds  thriving  in  almost  total 

absence  of  old-growth  forests:   Tillamook  Burn,  Clatsop  Plains,  Millicoma 

Tree  Farm,  etc.   The  real  issue  of  elk  habitat  is  obscured  by  the  use  of  a 

large,  popular  big-game  animal  as  a  surrogate  for  old-growth  forest  protectionism. 

On  p.  46,  73,  and  74  (DEIS)  mature  and  old-growth  forests  are  designated  as 
necessary  components  of  elk  habitat.   The  essential  ingredient  provided  by 
these  habitat  types  Is  survival  cover  that  is  defined  in  the  glossary  In  relation 
to  severe  winter  storms  of  heavy  snow  fall.   Structure  of  mature  and  old- 
growth  forest  provide  thermal  cover  and  limited  food  in  close  proximity.   In 
contrast  to  the  glossary  definition  (p. 74),  extreme  summer  temperatures  are 
considered  part  of  survival  cover. 


Climate  in  the  SYUs  is  temperature  marine  with  warm  summers  and  mild,  wet 
winters.   Precipitation  is  mostly  rain  and  "snow  is  generally  short-lived"(p.32) . 
Under  such  mild  weather  conditions,  "extremely  severe  winter  and  summer  weather 
.  .  ."(DEIS  p. 74)  would  occur  rarely.   Critical  evaluation  is  essential  If 
resource  allocation  for  extreme  weather  of  a  habitat  type  is  needed  so 


68-7 


seldom.   An  analogy  could  be  made  with  an  individual  planting  100  acres  in 
wheat  each  year  just  in  case  the  United  States  should  have  a  famine.   Each 
year  taxes  are  paid;  seed  is  purchased;  land  is  plowed  and  cultivated;  the 
crop  is  sprayed,  fertilized,  and  finally  combined  only  to  be  discarded  because 
the  famine  did  not  occur.   Is  survival  cover  worth  the  "just  In  case"  cost? 

The  definition  of  survival  cover  for  weather  extremes  is  not  precise.   In 
the  DEIS,  mature  and  old-growth  stands  are  always  both  used  as  meeting  the 
structural  requirements.   Referring  to  80-acre  blocks  of  120+  to  200+  year 
old  stands,  "These  stands  will  also  provide  the  stand  structure  (canopy  closure 
and  food  resources)  necessary  to  meet  the  survival  cover  needs  of  deer  and 
elk  during  severe  winter  weather" (MFP-NU-WL  p. 11).   So  apparently  mature  forest 
(116-195  years)  will  meet  survival  needs  and  old-growth  forest  is  not  necessary. 
In  addition,  RAA-NU-WL  (p. 18)  stated  about  severe  winter  weather  cover,  "Stands 
aged  50  to  200  years  old  will  fulfill  these  needs  efficiently,  though  older 
stands,  if  present,  are  preferred."  On  p.  103  in  the  same  document,  the  following 
statement  is  written,  "Although  younger  stands  (80+  years)  will  provide  summer 
thermal  cover  needs  for  deer  and  elk,  the  stands  aged  200+  years  old  are  needed 
to  totally  fulfill  the  animals'  need  for  cover  and  emergency  forage  during 
periods  of  severe  cold,  wet  or  snowy  weather  conditions."  This  statement 
by  BLM  says  (1)  that  80+  year-old  stands  will  meet  summer  thermal  cover  needs, 
(2)  that  cold  and  wet  are  also  a  reason  for  survival  cover,  and  (3)  that  the 
objective  is  to  totally  fulfill  all  needs  of  the  animals.   Whether  the  stands 
are  50+  or  80+  years  old,  these  are  far  younger  than  old-growth  stands.   Also, 
for  an  animal  whose  supposedly  optimum  habitat  is  Coast  Range  rainforest, 
it  is  difficult  to  imagine  rain  being  a  problem.  "Elk  appeared  indifferent 
to  average  coast  range  winter  weather  .  .  ."  (deCalesta  and  Witmer  1981  p. 38) 
and  furthermore  elk  used  cover  less  on  adverse  winter  days  than  on  mild  winter 
days.   Mandel  and  Kitcjien  (1979)  also  saw  elk  often  bedding  or  standing  in 
the  open  during  heavy  rain.   To  totally  fulfill  animals' habitat  requirements 
for  all  emergencies  is  impossible.   The  possibility  of  a  more  severe  weather 
event,  a  larger  forest  fire,  a  greater  volcanic  erruption,  a  new  disease  outbreak, 
a  more  efficient  competitor,  a  higher  flood,  etc.,  is  always  present.   Habitat 
needs  for  these  rare  contingencies  cannot  be  totally  met  even  with  unrestricted 
cost  and  unrestricted  resource  allocation. 


I  Thus,  survival  cover  (summer  and/or  winter?)  can  be  met  by  stands  50,  80, 
120,  or  100+  years  of  age  depending  upon  definition  and  criteria  used  in  the 
DEIS.   This  highly  specialized  survival  cover  could  be  a  possible  essential 
habitat  element  only  under  rarely  occurring  climatic  events.   Elk  are  not 
hindered  enough  to  move  by  snow  depths  less  than  18  to  24  inches  (Beall  1974, 
Leege  and  Hickey  1977,  Martinka  1976,  Schoen  1977).   Snow  depths  of  this  or 
greater  magnitude  are  rare  and  short-lived  for  southwestern  Oregon. 

Currently,  60%  of  Tyee  Area  is  in  80-year  or  older  forest  habitat  (DEIS  p. 45). 
Actually,  whether  elk  must  have  or  whether  elk  can  do  well  without  older  forest 
becomes  a  moot  question  with  so  much  mature  and  old-growth  forest.   This  is 
recognized  by  BLM  for  "no  impacts  (on  elk)  are  expected  in  the  short  term 
.  .  ."(DEIS  p. 79).   Short  term  is  defined  as  10  years  (DEIS  p. 64).   In  addition. 
Table  3-11  indicates  that  no  change  in  elk  population  will  occur  in  the  second 
decade  either.   Under  any  of  the  alternatives,  elk  habitat  will  not  be  changed 
enough  to  impact  elk.  populations  for  at  least  20  years. 

In  the  Tyee  "none  of  the  lands  scheduled  for  long  rotation  under  modified 
area  control  are  located  in  this  area.  .  .  ."(DEIS  p. 74).   Then  by  comparing 
Table  3-11  and  Table  3-9,  one  Interprets  that  mature  and  old-growth  forest 
can  be  reduced  by  approximately  60%  without  changing  the  elk  population. 

Further  support  comes  from  Schoen  (1977),  who  found  that  an  elk  herd  in  Western 
Washington  avoided  old-growth  stands  in  winter;  from  Harshman  and  Jubber  (1980), 
who  found  that  elk  survive  during  periods  of  heavy  snowfall  in  the  Western 
Oregon  Cascades  in  80+  year-old  stands;  and  from  deCalesta  and  Witmer  (1980), 
who  are  cited  as  proof  of  requirement  of  old-growth  forest.   In  fact  of  the 
latter,  the  research  year  had  only  a  trace  of  snow  making  meaningless  a  conclusion 
that  old-growth  stands  were  essential  to  provide  thermal  cover  and  forage 
under  extremely  heavy  snow  conditions. 

Summer  temperature  relationships  between  elk  and  vegetation  are  complex,  much 
more  so  than  air  temperatures  as  measured  by  deCalesta  and  Witmer  (1981)  in 
just  the  two  temperature  extremes  of  old-growth  stands  and  recent  clearcuts. 
Elk,  by  their  behavior,  adapt  to  temperature  (Beall  1976).   They  move  less 
in  midday  (deCalesta  and  Witmer  1981  p. 21, 31;  Schoen  1977  p. 132)  with  a  dally 


121 


activity  of  feeding  morning  and  evening  and  retreating  to  cover  in  midday 
(deCalesta  and  Witmer  1981  p. 37).   Thus,  high-midday  air  temperature  in  recent 
clearcuts  really  have  minor  impact  on  elk.   Not  only  may  cooler  mid- summer 
air  temperatures  be  found  in  old-growth  stands  but  in  younger-growth  stands 
as  well.   Second-growth  stands  may  significantly  moderate  weather  conditions 
with  the  dense  canopy  reflecting  solar  radiation,  thereby  creating  a  micro- 
climate more  favorable  for  elk  (deCalesta  and  Witmer  1981  p. 32, 35).   Elk  do 
respond  to  air  temperature.   Respond  is  the  key.   Elk  are  intelligent  animals 
found  over  a  wide  range  of  topographic  and  climatic  conditions.   Normally, 
they  are  not  found  at  midday  in  midsummer  in  the  midst  of  a  recent  clearcut 
where  air  timperatures  are  100-plus  degrees  F.  (Pedersen  1976).   On  the  contrary, 
if  old-growth  stands,  dense,  young-growth  stands,  hardwood  stands,  or  north 
slopes  are  available,  elk  will  be  in  the  shade.   The  shade  need  not  necessarily 
be  provided  by  old-growth  stands. 

As  a  result  of  the  large  acreage  of  mature  and  old-growth  forest  in  the  SYUs 
and  of  the  need  to  define  habitat  requirements  more  precisely,  no  immediacy 
exists  to  allocate  resources  for  elk  survival  cover  at  this  time.   Special 
timber  harvest  regulations  proposed  for  the  Tyee  Area  such  as  smaller  clearcuts, 
distance  to  cover,  cover  width,  road  closure,  etc.,  will  enhance  populations 
in  this  significant  elk  area. 

In  conclusion,  enlightenment  is  provided  by  the  importance  of  the  Tioga  Management 
Unit  of  ODFW  to  Roosevelt  elk  kill  in  Oregon.   It  is  a  "premier  area  as  it 
contributes  an  average  of  51.5%  of  the  Roosevelt  elk  kill,  .  .  ."(in  Oregon) 
(RAA-DL-WL  p. 21).   This  Unit  also  provides  over  half  of  the  elk  harvest  in 
the  Dillard  Resource  Area.   The  same  paragraph  continues,  "It  should  be  noted 
however  that  the  bulk  of  the  recorded  kill  came  from  lands  owned  by  the  Weyerhauser 
Company  and  not  those  (BLM  lands)  within  the  planning  unit."  These  private 
forest  lands  that  grew  most  of  the  elk  were  not  mature  or  old-growth  forests 
but  lands  that  had  been  clearcut  over  the  past  25  years. 

D.   Mature  and  Old-Growth  Forest  Corridors 


land  allocated  for  corridors  is  commendable  and  has  been  partially  successful. 
The  basic  question  is  the  concept  of  corridors.   True,  the  habitat  blocks 
are  "located  in  loosely  arranged  corridors  .  .  ."(DEIS  p. 124)  or  "generally 
located  within  a  corridor  .  .  ."(DEIS  p. 15).   Still,  1,757  acres  of  old-growth 
forest  and  9,415  acres  of  mature  forest  are  single-use  allocations  solely 
for  corridors.   Comparing  location  of  large  blocks  of  old-growth  forest  with 
location  of  spotted  owl  areas  gives  the  impression  that  some  old-growth  areas 
were  chosen  not  as  the  best  owl  habitat  but  to  fill  corridor  gaps. 

Large  old-growth  blocks  (approximately  600  acres  each)  are  cited  (MFP-NU- 
WL  p. 19)  as  a  requirement  for  spotted  owl,  fisher,  marten,  and  possibly  cougar. 
The  fisher  population  level  is  at  or  near  zero  at  the  present  time  (RAA-DL- 
Wl  p. 41)  and  may  have  already  passed  from  existence  (RAA-DL-WL  p. 95).   Both 
the  marten  (RAA-DL-WL  p. 41)  and  cougar  (MFP-NU-WL  p. 19)  commonly  range  broadly 
across  upland  forests  ranging  in  age  from  clearcuts  to  old-growth  stands. 
Only  the  spotted  owl  remains,  and  its  habitat  requirements  have  been  discussed. 
Elk  are  doing  well  under  a  fragmented  forest-island  habitat  that  the  corridor 
system  supposedly  would  correct.   From  RAA-DR-WL  (p. 19)  the  following  sentences 
are  quoted,  "The  present  distribution  of  elk  in  western  Oregon  is  characterized 
by  population  concentration  centers  which  occur  as  islands  across  forest  lands 
of  varying  serai  stages.   The  lack  of  elk  in  some  seemingly  acceptable  habitat 
has  remained  unexplained." 

At  this  time  the  proposed  corridor  system  is  a  test  or  experiment  and  as  yet 
an  essentially  unplanned  experiment.   Wildlife  habitat  management  plans  and 
PAA  analysis  have  not  been  completed  for  corridor  lands.   The  option  to  form 
a  corridor  system  will  never  be  foreclosed  because  mature  and  older  forests 
are  renewable.   Extinction  is  not  an  issue  for  no  species  in  the  SYUs  are 
found  only  in  the  Roseburg  District  or  are  threatened  by  extinction.   During 
this  time  of  recession  and  budgetary  restraint,  a  corridor  system  is  a  costly 
experiment  with  little  chance  of  fulfilling  the  intended  purpose  because  of 
the  checkerboard  nature  of  OiC  lands. 


Although  it  is  presented  in  an  off-hand,  low-profile  manner,  apparently  a 
corridor  system  is  envisioned  for  the  SYUs.   Attempts  to  overlap  and  joint-use 


E.   Summary  of  Old-Growth  and  Wildlife  Acreage 

What  is  sufficient  old-growth  forest  to  meet  wildlife 


eeds  is  not  easily 


68-9| 
68-10 


answered.   The  DEIS  makes  the  statement  (p. 74)  that  only  Alternatives  6,  7, 
and  8  would  maintain,  over  the  long-term,  populations  of  animals  whose  optimum 
habitat  is  mature  and  old-growth  habitat.   From  Table  3-9  this  would  be  interpreted 
that  currently  enough  is  known  about  old-growth  species  to  say  that  100  years 
from  now  70,000  acres  of  old-growth  forests  will  be  required.   The  accuracy 
of  this  long-term  prediction  based  on  the  present  scant  data  Is  highly  questionable. 
Elk  populations  would  only  decline  20%  (Tab. 1-5)  in  Alternatives  4  and  5. 
Would  this  be  past  the  population  threshold  and  elk  would  cease  to  exist  in 
,the  SYUs?   Eighteen  pair  of  spotted  owl  (Tab. 1-5)  would  remain  at  100  years 
lunder  Alternatives  3  and  4.   Is  the  spotted  owl  not  then  a  good  old-growth 
|indicator  species?   From  what  is  known  it  has  larger  and  more  stringent  old- 
growth  habitat  requirements  than  other  species.   According  to  the  DEIS  (p. 71), 
Alternatives  3  and  4  would  also  "provide  an  adequate  representation  of  the 
original  old-growth  systems."  Yes,  prediction  of  habitat  for  wildlife  populations 
a  century  in  the  future  is  filled  with  possible  errors. 

Hence,  whether  for  spotted  owls,  elk  habitat,  or  corridors,  there  seems  to 
be  little  prudent  support  for  allocating  Commercial  Forest  Land  to  a  Constrained 
Timber  Production  Base  for  wildlife  purposes.   The  amount  of  forest  timber 
harvest  lost  under  the  Constrained  Base  is  significant.   This  EIS  for  the 
Timber  Management  Plan  "Is  considered  applicable  for  the  decade  .  .  ."(DEIS 
p. 26).   At  the  end  of  the  ten-year  period  a  more  accurate  assessment  of  wildlife 
needs  will  be  possible.   Unreasonable  demands  have  been  placed  on  wild] 
biologists  the  past  five  years  to  categorize  and  quantify  wildlife  habitat. 
Studies  of  old-growth  systems  themselves  have  been  recent  (DEIS  p. 42),  let 
alone  studies  on  animals  and  relationships  within  the  old-growth  system.   Many 
of  the  guesses,  best  estimates,  assumptions,  district  biologists'  opinions, 
etc.,  can  in  a  decade  be  sound  biological  fact  with  resultant  sound  resource 
allocation.   Meanwhile,  during  the  next  decade  habitat  alteration  will  not  be 
extensive  enough  to  harm  knowingly  any  species  or  community. 


Ill   ELK  AND  ROAD  SYSTEMS 


Harrassment  of  wildlife  (elk)by  vehicles  is  at  this  time  a  confusing, 
understood  subject.   Research  does  present  conflicting  results,  but  more  impor- 
tantly the  visual  experience  of  many  people  who  regularly  see  elk  along  major 
highways  makes  it  difficult  to  convince  the  public  that  elk  use  is  significantly 
affected  within  h  mile  along  each  side  of  lightly  used  logging  roads.   The 
following  quotation  from  the  August  8,  1982,  Oregonian  illustrates  this  point: 
Tourists  are  getting  an  eyeful  on  coastal  highways  and  b 
this  summer,  as  Roosevelt  elk  wade  across  the  country  scenery  amid 
farms  and  cattle. 

The  accompanying  photograph,  for  example,  was  taken  a] 
U.S.  101,  a  mile  south  of  Tillamook,  where  this  four-point  bull 
has  adopted  a  herd  of  young  dairy  princesses. 

It's  not  common,  but  neither  is  it  unusual,  for  elk  bulls 
to  act  this  way,  say  biologists.   The  paternal  instincts  wear  off 
with  time,  as  the  elk  realizes  his  adopted  charges  don't  re 
care  about  him  one  way  or  another. 

The  Reedsport  herd  has  also  been  regularly  hanging  around 
its  usual  field  haunts  alongside  Oregon  38,  a  few  miles  east 
town. 

Wildlife  biologists  also  seem  to  have  a  difficult  time  accepting  elk  avoidance 

of  habitat  near  roads.   Hershey  and  Leege  (1976)  used  truck  and  trailbike 

to  observe  elk  on  eleven  of  eighteen  observation  routes  and  more  recently 

BLM  and  ODFW  employees  Smithey,  Wisdom,  and  Hines  (1982)  conducted  a  study 

on  Roosevelt  Elk  and  Black-tailed  Deer  Response  to  Habitat  Changes  Related 

to  Old-growth  Conversion  in  South  Western  Oregon.   The  study  was  conducted 

by  road  counts.   If  elk  avoid  using  habitat  near  roads,  roadside  census  techniques 

would  be  highly  inaccurate. 


The  scientific  literature  is  conflicting.   Studies  rrass- 

ment  is  significant  are  summarized  by  Irwin  and  Peek  (1979),  Lyon  (1979), 
Pedersen  et  al.  (1979),  and  Perry  and  Overly  (197(.  the  studies  referred 

to  were  on  Rocky  Mountain  elk  east  of  the  Cascade  Range  where  "topography 


15  - 


122 


ili  deap  valleys  and  high  steep  ridges  .  .  ."(Perry  and  Overly 
1976  p. 62).   In  addition  to  larger  topography,  vegetation  is  more  sparse  In 
these  areas  than  in  the  Coast  Range.   For  example,  old-growth  stands  in  Northern 
Idaho  had  a  visibility  radius  of  100  feet  while  second-growth  stands  had  a 
visibility  radius  of  40  feet.   Hence,  young-growth  stands  were  used  as  hiding 
cover  more  than  other  vegetation  types  (Irwin  and  Peek,  1979).   Ward  (1976) 
concluded  that  "as  long  as  the  vehicle  is  moving,  elk  apparently  feel  relatively 
safe"(p.38).   In  this  particular  four-year  study  In  Wyoming,  elk  were  seen 
or  telemetery  located  44  times  from  the  road  to  200  yards,  34  times  from  200 
yards  to  440  yards,  56  times  from  440  yards  to  880  yards  (twice  the  distance), 
and  57  times  from  880  yards  to  1760  yards  (four  times  the  distance).   According 
to  this  report,  per  amount  of  area,  elk  used  area  near  the  roads  more  than 
area  farther  away.   The  conclusion  of  a  study  on  roads  and  wildlife  in  Arizona 
was  "In  late  summer  and  fall,  traffic  increased  significantly.   However,  it 
is  doubtful  that  this  increase  has  an  adverse  effect  on  wildlife  production 
.  .  ."(Burbridge  and  Neff  1976  p. 56).   Schoen  (1977)  found  heavy  use  of  roads 
as  travel  routes  in  western  Washington  during  the  winter  whether  the  roads 
had  been  plowed  or  not  and  also  stated,  "Wapiti  have  frequently  been  observed 
within  300  feet  of  a  moderately  used  road,  separated  by  cover,  and  appeared 
to  show  little  concern  for  vehicular  traffic  unless  a  vehicle  stopped  .  . 
."(p. 199).   To  continue  from  this  same  western  Washington  study,  "on  the  whole, 
especially  in  areas  where  dense  vegetation  provides  cover  and/or  impedes  travel; 
it  appears  that  wapiti  will  use  low  traffic  or  closed  roads  as  travel  lanes 
or  trails  .  ,  ."(p. 200).   Shoen  also  noted  that  displacement  movements  by 
current  logging  operations  were  usually  one-half  mile  or  less  and  that  elk 
were  often  observed  within  one-half  mile  of  active  logging  when  shielded  by 
vegetative  cover  or  topography.   Elk  in  Olympic  National  Park  were  observed 
by  Jenkins  and  Starky  (1980)  to  bed  often  in  spruce-hemlock  stands  within 
audible  range  of  human  voices  and  traffic  and  appeared  to  be  accustomed  to 
activity  on  the  road. 


be  the  most  abundant  habitat  type  on  the  SYUs  in  future  yearn  (DEIS  App 
Proper  road  and  vegetation  management  would  certainly  narrow  the  impact  zone 
of  roads  on  elk.   "Losses  to  thlB  cause  (harrassment)  would  not  be  expected 
to  be  large  or  significant  to  the  population  as  a  whole.  .  .  ."(OBIS  p. 72) 
could  readily  be  applied  to  the  use  of  elk  habitat  and  roads. 

In  brief,  road  systems  may  reduce  elk  use  of  nearby  habitat  under  open,  long- 
sight-distance,  high-traffic  conditions.   At  the  same  time,  smaller  topography, 
rapid  revegetation,  abundant  hiding  cover,  and  low-vehicular  traffic  permit 
elk  use  nearer  to  road  systems.   Elk  with  a  comparatively  large  home  range 
can  easily  move  away  from  a  road  during  periods  of  traffic  or  during  the  day 
and  then  move  nearer  the  road  at  night  or  low-traffic  times  to  use  the  hat- 
Not  only  do  13-to- 30-year-old  trees  provide  hiding  cover,  but  darkness  (Pedersen, 
1976)  is  also  a  ubiquitous  reliable  hiding  cover.   Besides  being  hiding  cover, 
darkness  is  also  thermal  cover  as  shown  by  the  statement,  "Elk  used  clearcut 
areas  at  night  but  preferred  the  security  and  milder  temperatures  of  dense 
conifer  stands  during  the  day"  (Edgerton  and  McConnell  1976  p. 5).   Schoen 
(1977)  found  that  elk  actually  preferred  open  regions  (clearcuts)  at  night. 
Broad  generalized  statements  that  elk  use  is  reduced  within  one-half  mile 
of  roads  and  that  up  to  75%  of  an  area  would  have  reduced  elk  use  because 
of  roads  are  extrapolation  of  data  from  a  different  elk  in  a  different  topography, 
OO  II  In  different  vegetative  types,  and  in  different  climates  than  the  Coast  Range. 
Management  of  roads  and  of  forest  treatment  practices  and  applying  what  is 
known  about  elk  behavior  to  a  specific  area  (as  the  Tyee  Area)  can  greatly 
limit  road-elk  conflict. 


Some  interruption  of  normal  elk  behavior  due  to  vehicular  harrassment  does 
occur  under  certain  circumstances.   Pedersen  (1979,  1979b)  and  Black  et  al. 
(1976)  have  road  management  recommendations  that  are  being  incorporated  Into 
the  Tyee  Area  to  reduce  conflict.   Hiding  and  escape  cover  (DEIS  p. 45)  will 


to  significantly  affect  the  stand  or  species  compositio 
Area"(DEIS  p. 70). 


of  the  entire  Roseburg 


IV  INTENSIVE  FOREST  MANAGEMENT  AND  WILDLIFE 


Intensive  forest  management  is  the  basic  premise  of  the  Proposed  Action:   249 
MM  bd.  ft.  from  333,319  acres  of  Commercial  Forest  Land  compared  to  the  No 
Change  Alternative  with  201  MM  bd.  ft.  from  390,984  acres.   Wildlife  and  their 
habitat  will  be  influenced  by  intensive  forest  management,  yet  as  a  whole 
the  impact  will  be  localized  and  will  not  be  severe.   Important  habitat  areas 
for  special  uses  or  special  species  are  protected  by  MFP  withdrawals  in  all 
alternatives  except  5.   Additional  protection  for  other  specialized  uses  is 
allocated  as  Constrained  Timber  Production  Base  in  all  alternatives  except 
1  and  5.   Not  every  forest  management  treatment  will  be  applied  to  every  acre 
of  Commercial  Forest  Land  (DEIS  p. 19),  and  as  an  example  Alternative  2  has 
63,000  acres  that  are  not  in  the  intensive  timber  harvest  base.   It  is  worthwhile 
examing  some  of  the  forest  treatments  and  the  result  of  these  treatments  on 
wildlife. 

A.  Slash  Burning 

Slash  burning  eliminates  most  live  vegetation  and  associated  animal  populations 
for  a  short  time.   Nevertheless,  "this  would  last  less  than  one  growing  season, 
after  which  a  vigorous  growth  of  grasses  and  forbs  would  appear  and  animal 
populations  adapted  to  early  successional-stage  vegetation  would  be  reestablished" 
(DEIS  p. 76).   Forage  for  elk  and  deer  is  generally  increased  and  woody  material 
that  obstructs  large  animal  movement  is  reduced.   As  a  whole,  burning  impacts 
are  very  short  term  with  subsequent  enhancement  for  important  game  species. 
The  trend  toward  spring  or  fall  light  burns  reduces  impact. 

B.  Artificial  Regeneration 

Artificial  regeneration  usually  accelerates  succession  through  early  stages, 
but  since  cutting  will  continue,  other  acres  will  be  continuously  beginning 
early  succession.   A  rotating  source  will  be  available.   Impact  is  summarized 
by  "the  artificial  regeneration  program  on  BLM-administered  lands  is  not  expected 

-  18  - 


68-12 


68-13 


C.  Precommercial  Thinning 

Precommercial  thinning  is  credited  with  increasing  bird  and  small  mammal  use 

but  hindering  deer  and  elk  movement.   Crouch  (1974)  is  the  reference  cited 

in  the  DEIS  for  the  conclusion  that  slash  impedes  deer  and  elk  movement.   The 

article  is  entirely  on  deer;  the  word  elk  is  not  even  used  so  this  reference 

is  not  applicable  to  elk.   On  the  other  hand,  Swanson  (1970)  does  write  that 

sites  with  moderate  amounts  of  logging  debris  generally  received  most  elk 

use  and  those  with  heavy  amounts,  the  least  use.   Areas  of  patchy  debris  distribution 

had  more  use  than  sites  with  uniform  debris  distribution.   Whether  or  not 

precommercial  thinnings  present  a  major  obstruction  to  deer  or  elk  would  depend 

mainly  upon  the  pre-thinning  density  of  the  stand.   Precommercial  thinning 

after  trees  are  too  large  (15  years?)  or  on  extremely  dense  stands  (2,000 

stems  per  acre)  can  restrict  potential  habitat  use.   Berg  (1969)  noted  that 

slash  from  precommercial  thinning  was  quickly  beaten  to  the  ground  and  in 

2  to  3  years  the  fine  material  is  decomposed  enough  so  that  slash  debris  is 

not  a  problem.   Since  only  an  average  of  approximately  11   of  the  SYUs  acreage 

would  be  precommercially  thinned  in  any  one  year,  it  would  not  cause  a  significant 

habitat  impact. 

D.  Fertilization 

Fertilization  proposed  at  10-year  intervals  with  impacts  lasting  for  an  average 
of  7  years  (DEIS  p. 70)  will  increase  growth  and  palatability  of  many  plant 
species  (DEIS  p. 77).   This  will  provide  additional  forage  for  wildlife  and 
will  hasten  the  decomposition  of  thinning  slash. 


E.   Commercial  Thinning 

Commercial  thinning,  between  30  and  60  years,  that  removes  30Z  to  40*  of  the 
basal  area  is  discussed  In  the  DEIS  as  resulting  in  lower  deer  and  elk  populations. 
Edgerton  (1972)  and  Edgerton  and  McConnell  (1976)  studies  In  northeastern 
gg-14|0regon  are  ciced.   Not  all  research  has  reached  the  same  conclusion.   Partial- 
cuts  were  more  acceptable  to  elk  than  clearcuts  in  western  Montana  (Marcum 
1976);  in  northern  Idaho,  stands  treated  by  shelterwood  method  produced  nearly 


123 


as  much  herbaceous  cover  as  clearcuts  (Irwin  1976);  in  Arizona,  selective 

cutting  increased  understory  vegetation  for  11  to  15  years  (Reynolds  1962); 

in  northeastern  Oregon,  timber  stands  with  less-dense  cover  were  used  as  forage 

a. 

areas  (Pedersen  1979);  In  western  Washington,  elk  during  the  summer  used  open 
and  sparse  canopy  habitat-types  in  the  same  proportion  in  which  they  occurred 
while  closed  canopy  habitats  were  avoided  (Schoen  1977). 

Thus,  a  total  negative  impact  of  partial-cuts  on  elk  and  deer  is  questionable. 

The  habitat  type,  the  location,  the  climate,  the  adjacent  land  use  and  other 

variables  must  be  considered.   Under  many  situations  commercial  thinning  may 

be  more  helpful  than  harmful  to  wildlife.   The  balance  between  forage  and 

cover  habitats  and  available  supply  of  both  along  with  the  ability  of  deer 

and  elk  to  move  between  habitats  in  order  to  maintain  this  balance  is  complex. 

An  overall  negative  influence  upon  wildlife  Is  not  supported  by  existing  biological 

data. 

An  impact  of  commercial  thinning  upon  selected  birds  is  also  indicated  in 
the  DEIS.   The  authority  cited  is  Franzreb  and  Ohmart  (1978),  a  study  in  Arizona 
that  compared  bird  life  in  an  area  before  and  after  logging.   Before  logging, 
density  was  896  trees  per  acre;  after  logging,  density  was  268  trees  per  acre. 
Even  though  the  total  bird  population  was  far  smaller  in  the  partial-cut  area, 
thinning  led  to  an  increase  in  tree-species  diversity  and  no  change  in  bird 
species  diversity.   So  tree  thinning  reduced  total  bird  population  but  not 
the  number  of  bird  species.   In  a  study  in  New  York  where  25%,  50%,  75%,  and 
100%  of  the  trees  were  removed  by  logging,  Webb  et  al.  (1977)  concluded  that 
no  bird  species  was  eliminated  by  logging  and  that  "numbers  of  species  and 
diversity  indices  were  higher  in  logged  areas  and  were  positively  correlated 
with  increased  logging  intensity"  (p. 32).   Areas  with  25%  and  50%  tree  removal 
would  be  comparable  to  commercial  thinning.   Mauer  et  al.  (1981)  noted  that 
the  difference  in  bird  populations  between  a  selective-cut  area  and  a  mature 
forest  was  the  addition  of  early-regrowth  adapted  species  to  the  already  present 
mature-forest  adapted  species.   The  two-bird  communitites  remained  very  similar. 
From  another  study  the  conclusion  was  "in  summary,  we  found  few  differences 
in  the  total  density  or  richness  of  the  breeding  birds  of  a  hardwood  forest 
that  was  affected  by  several  forestry  practices,  including  clear-cutting, 


strip  cutting,  and  thinning"  (Freeman  et  al.  1981  p.  310).   Obligate  forest 
birds  had  intermediate  mixtures  in  thinned  plots  where  thinning  was  removal 
of  45%  of  the  basal  area.   Szaro  and  Balda  (1979)  recommend  that  only  30% 
of  the  basal  area  be  removed  to  maintain  and/or  increase  bird  populations 
in  a  Ponderosa  pine  forest. 

Commercial  thinning  is  also  credited  with  Impacting  nesting  of  Cooper's  and 
sharp-shinned  hawks.   Jactaan  and  Scott  (1975)  list  seven  out  of  ten  sharp- 
shinned  hawk  nests  as  being  in  young,  even-aged  conifer  stands  with  single- 
layered  canopies  while  Cooper's  hawks  nested  in  Douglas-fir  sjres  with  a  mean- 
stem  density  of  217  per  acre.   The  latter  density  of  217  trees  per  acre  (approximately 
15  feet  apart)  is  not  a  particularly  dense  stand.   In  fact,  this  af ter-thinnlng 
tree  density  (approximately  200  trees  per  acre)  is  nearly  the  same  den 
used  in  the  DEIS  to  Indicate  that  commercial  thinning  is  harmful  to  accipiter 
nesting  habitat.   Similarly,  the  other  reference  to  indicate  commercial  thinning 
harms  bird  habitat  (Franzreb  and  Ohmart  1978)  had  an  after-thinning  density 
of  268  stems  per  acre.   The  logical  conclusion  is  that  the  thinned  forest 
habitat  in  the  latter  has  more  stems  per  acre  (268)  than  the  dense  (as  referred 
to  in  the  DEIS  p. 74)  habitat  (217)  in  the  previous  reference.   In  other  words, 
density  is  relative. 

Commercial  thinning  of  20%  to  50/.  of  the  basal  area  can  alter  forest  habitat. 
But  as  has  been  shown  by  the  previous  references,  the  impact  may  or  may  not 
occur.   It  may  be  positive  or  negative.   It  often  is  slight.   And  it  is  species 
specific,  but  overall  does  not  eliminate  species.   Obviously,  broad  statements 
that  commercial  thinning  has  negative  impact  are  not  supported  by  biological 
evidence.   Also,  to  be  remembered  is  that  on  an  average  only  approximately 
0.1%  of  the  Timber  Production  Base  will  be  commercially  thinned  each  year. 

Intensive  forest  management  treatments  will,  as  a  whole,  not  significantly 
impact  wildlife.  Animals  will  temporarily  compress  or  expand  home  ranges 
and  increase  or  decrease  population  levels  over  the  short  term  as  habitat 
is  available.  Wildlife  is  adaptable  and  is  capable  of  moving  to  avoid  or 
to  use  changing  habitats  whether  the  habitat  is  changed  by  succession  or  by 


managed  treatment.   Two  statements  in  the  DEIS  are  worthy  of  note  on  this 
subject.   Intensive  timber  management  practices  will  not^  eliminate  hardwood 
trees,  shrubs,  and  herbaceous  vegetation  (p. 72),  and  "vegetation  which  is 
disturbed  or  destroyed  by  timber  management  activities  would  eventually  be 
replaced  by  other  plants  of  the  same  species  and  natural  succession  would 
restore  community  structure  until  the  next  harvest  stage" (DEIS  p. 71).   Therefore, 
treatments  may  alter  vegetation,  but  natural  succession  will  return  the  same 
species  to  the  treated  areas. 


V   RIPARIAN  AREA  MANAGEMENT  AND  FISHERIES 


Riparian  areas  and  their  management  as  proposed  under  Alternatives  2,  3.  <. , 
and  7  will  adequately  meet  the  many  uses  of  the  streamside  acres.   The  18,332 
of  riparian,  plus  3,682  acres  of  VRM  II,  plus  2,772  acres  for  osprey  and  heron 
provide  24,786  acres  that  are  essentially  riparian  area.   In  addition,  the 
2,912  acres  that  are  completely  protected  for  bald  eagle  would  also  be  mainly 
riparian  area.   The  small  acreage  proposed  for  clearcut  and  partial-cut  would 
not  disrupt  the  integrity  of  the  riparian  system  and  its  many  functions  while 
still  permitting  multiple-use  in  the  form  of  limited,  regulated  timber  harvest. 
Sediment  would  be  trapped  by  the  riparian  areas  under  Modified  Area  Control 
as  indicated  (DEIS  p. 68),  and  no  increase  in  stream  water  temperature  would 
be  expected  as  indicated  on  p.  78.   Forest  harvest  along  first-  and  second- 
order  streams  is  cutting  vegetation  that  is  more  like  upland  habitat  than 
riparian  habitat  (DEIS  p. 75);  hence,  possible  impact  is  lessoned. 


Habitat  improvements  of  various  types  as  suggested  in  the  MFP-Fisheries  will 
improve  the  instream  fishery  habitat  and  blockage  removal  will  open  new  habitat. 
Much  of  the  low  summer  water  flow  is  a  result  of  domestic  and  agricultural 
use  over  which  BLM  has  little  control. 


6815 


The  summary  statement  on  environmental  consequences  (DEIS  p. 79)  does  not 

to  agree  with  data  presented.   Fish  populations  would  be  expected  to  dt- 

under  Alternative  1,  2,  and  3  because  of  increased  temperatures  and  sedimentation, 

and  under  Alternativew  4 ,  6,  7,  and  8  fish  populations  would  increase.   In 

contrast,  the  DEIS  (p. 78)  states,  "Water  temperatures  would  not  increa 

Alternatives  2,  3,  4,  6,  7,  or  8  were  selected."  The  difference  in  amount 

of  sediment  between  Alternatives  3  and  4  is  only  3".   With  the  current  st3te 

of  the  art,  it  is  impossible  to  predict  the  influence  of  sediment  upon  fishes 

with  anywhere  near  a  plus-or-minus-3';  accuracy. 


23  - 


124 


68  16 


In  addition,  the  statement  (DEIS  p. 75)  that  the  proposed  management  of  riparian 
areas  for  Alternatives  2,  3,  4,  and  7  would  substantially  alter  riparian  habitats 
can  be  questioned.   Carefully  controlled  partial-cut  (and  other  management 
restrictions)  on  (>X   of  the  total  riparian  acres  and  clearcuttlng  of  0.072 
annually  could  hardly  produce  substantial  alteration  on  the  whole  riparian 
area.   The  proposed  riparian  areas  and  their  management  under  Alternatives 
2,  3,  4,  and  7  will  maintain  and  enhance  terrestrial  wildlife,  snag-dependent 
species,  water  quality,  streambank  protection,  and  fish  populations. 


VI   CONCLUSIONS 


(1)  BLM  is  commended  for  considering  and  applying  some  innovative  management 
and  for  the  Improvement  of  this  DEIS  over  previous  Environmental  Statements. 

(2)  Acres  allocated  for  the  Intensive  Timber  Production  Base  are  of  prime 
Importance  as  the  foundation  of  timber  harvest. 

(3)  Acres  removed  from  the  Intensive  Timber  Production  Base  under  all  alternatives 
except  1,  2,  and  5  are  major  and  significant. 

(4)  The  SYUs  presently  have  47£  of  Che  area  in  mature  and  old-growth  forests; 
this  acreage  will  remain  high  under  all  alternatives  through  the  first  decade. 

(5)  A  comparatively  high  number  of  owls  exist  in  the  SYUs  and  will  remain 
high  through  the  first  decade. 

(6)  Much  is  not  known  about  spotted  owls  and  about  old-growth  forests  with 

the  consequence  that  the  relationship  between  wildlife  and  old-growth  is  unclear. 

(7)  The  spotted  owl  is  not  listed  nor  has  It  been  proposed  for  listing  under 
the  Federal  Endangered  Species  Act.   In  fact,  the  FWS  says  that  the  spotted 
owl  would  not  qualify  for  Federal  listing. 

(8)  For  the  next  decade,  allocation  of  resources  solely  for  the  spotted 
owl  seems  unnecessary  and  ill-advised. 

(9)  It  has  not  been  shown  that  elk  must  have  old-growth  forest  as  survival 
cover.  Because  elk  are  adaptable,  no  decline  in  harvest  is  projected  during 
the  next  two  decades. 

(10)  During  either  summer  or  winter,  elk  respond  to  weather  conditions  by 
diurnal  or  longer  movemenCs  to  locations  that  fill  their  temperature  needs. 
These  cover  needs  can  and  often  are  met  by  habitat  types  other  than  old-growth 
habitat. 

(11)  A  proposed  wildlife  corridor  system  has  little  chance  of  functioning 
because  of  the  checkerboard  nature  of  BLM  lands. 

(12)  A  corridor  system  is  a  costly  and  essentially  unplanned  experiment. 

(13)  For  any  of  the  reasons  reported  in  the  DEIS,  there  seems  little  prudent 
support  for  allocating  old-growth  foresc  to  a  Constrained  or  Non-harvest  Base 
for  wildlife  purposes. 

-  25  - 


(14)  A  generalized  statement  that  elk-habitat  use  is  noticeable  reduced  by 
logging  road  systems  is  not  supported  by  common  knowledge  nor  by  the  literature. 
Road  harrassment  impacts  may  be  much  less  than  presented  in  the  DEIS. 

(15)  Intensive  forest  management  may  be  either  helpful  or  harmful  to  wildlife 
habitat.   Negative  influence,  if  present,  is  nearly  always  short-lived  and 
localized. 

(16)  Succession  will,  over  time,  return  Che  same  plant  and  animal  community 
to  a  management-treated  area.  As  a  result,  old-growth  forest  is  a  renewable 
resource. 

(17)  Acres  allocated  and  management  proposed  for  the  riparian  areas  will 
adequately  protect  and  enhance  the  many  important  uses  associated  with  streamside 
and  downstream  areas. 


LITERATURE  CITED 


Beall,  R.  C. 

1974.   Winter  habitat  use  by  a  western  Montana  elk  herd. 
Univ.  Mont.,  Missoula. 


Ph.D.  Thesis. 


Beall,  R.  C. 

1976.   Elk  habitat  selection  In  relation  to  thermal  radiation.   I_n  Proceedings 
of  the  elk-logging-roads  symposium,  p.  97-100.   Univ.  Idaho,  Moscow. 


Berg,  A.  B. 

1969.   Thinning  in  precommercial  stands. 
Northwest,  p.  79-87.   Coop.  Extension  Ser 


Woodland  handbook  for  the  Pacific 
Oreg.  State  Univ.,  Corvallis. 


Black,  H. ,  R.  Scherzinger,  and  J.  W.  Thomas 

1976.   Relationships  of  Rocky  Mountain  elk  and  Rocky  Mountain  mule  deer  habitat 
to  timber  management  in  the  Blue  Mountains  of  Oregon  and  Washington.  lr\ 
Proceedings  of  the  elk-logging-roads  symposium,  p.  11-31.   Univ.  Idaho,  Moscow. 

Burbridge,  W.  R.  and  D.  J.  Neff 

1976.   Coconino  National  Forest — Arizona  Game  and  Fish  Department  cooperative 
roads — wildlife  study.  _In_  Proceedings  of  the  elk-logging-roads  symposium, 
p.  44-57.   Univ.  Idaho,  Moscow. 

Crouch,  G.  L. 

1974.  Interaction  of  deer  and  forest  succession  on  clearcuttings  in  the 
Coast  Range  of  Oregon.  I_n  Wildlife  and  forest  management  in  the  Pacific 
Northwest,  p.  133- 138.   Oreg.  State  Univ.,  Corvallis. 

deCalesta,  D.  S.  and  G.  Witmer 

1980.   The  relationship  of  stand  development  to  habitat  requirements  of  elk 
in  the  Douglas-fir  region  of  the  Coast  Range  of  Oregon.   Final  Report,  FW-PNW- 
Grant  No.  18,  58  p.  +  tab.  and  fig.,  Dept.  Fish  and  Wildl. ,  Oreg.  State  Univ., 
Corvallis. 


Edgerton,  P.  J. 

1972.   Big  game  use  and  habitat  changes  in  a  recently  logged  mixed  conifer 
forest  in  northeastern  Oregon.   Proceedings  52nd  Annu.  Conf.  West.  Assoc. 
State  Fish  and  Game  Coram.,  p.  239-246,  Portland,  Oreg. 


Edgerton,  P.  J.  and  B.  R.  McConnell 


gerton,  P.  J.  and  B.  R.  McConnell 

1976.   Diurnal  temperature  regimes  of  logged  and  unlogged  mixed  conifer  stands 

on  elk  summer  range.   USDA  For.  Serv.  Res.  Note,  PNW-277.   6  p.   Pac.  Northwest 

Vnr-         9nA     D-inas     Pvn         ^f-n  Pnrfl  anrl         Or«a 


.  range 
For.  and  Range  Exp.  Stn 


Portland,  Oreg. 


125 


Franzreb,  K.  E.  and  R.  0.  Ohnart 

1978.   The  effects  of  timber  harvest  on  breeding  birds 
forest.   Condor  80:431-^11. 


nixed  coniferous 


Freedraan,  B.,  C.  Beauchanp,  I.  A.  McLaren,  and  S.  I.  Tingley 

1981.  Forestry  management  practices  and  populations  of  breeding  birds  in  a 
hardwood  forest  in  Nova  Scotia.   Can.  Field-Nat.  95(3) :307~31 1 . 

Harshman,  E.  P.  and  R.  N.  Jubber 

1980.  Roosevelt  elk  and  blacktailed  deer  guidelines  for  timber,  recreation, 
and  road  management.   (Draft)   63  p.   Willamette  Nat'l.  For.  and  ODFW. 

Hershey,  T.  J.  and  T.  A.  Leege 

1976.  Influences  of  logging  on  elk  on  summer  range  in  north-central  Idaho. 
In  Proceedings  of  the  elk- logging-roads  symposium,  p.  73-80.  Univ.  Idaho, 
Moscow. 

Irwin,  L.  L. 

1976.  Effects  of  intensive  silviculture  on  big  game  forage  sources  in  northern 
Idaho,  In     Proceedings  of  the  elk- logging-roads  symposium,  p.  135-142.   Univ. 
Idaho ,  Moscow. 

Irwin,  L.  L.  and  J.  M.  Peek 

1979.  Relationship  between  road  closure  and  elk  behavior  in  northern  Idaho. 
In  North  American  elk:   ecology,  behavior  and  management,  p.  199-205.   Univ. 
Wyo. ,  Laramie. 

Jackman,  S.  M.  and  J.  M.  Scott 

1975.  Literature  of  twenty-three  selected  forest  birds  of  the  Pacific  Northwest. 
USDA  For.  Serv.  Reg.  6.   382  p.   Portland,  Oreg. 

Jenkins,  K.  and  E.  Starkey 

1980.  Roosevelt  elk  of  the  Hoh  Valley,  Olympic  National  Park.  Final  Report, 
Contract  No.  CX9000-7-0085,  NPS,  Oreg.  Coop.  Park  Studies  Unit.  32  p.  Oreg. 
State  Univ.,  Corvallis. 

Leege,  T.  A.  and  W.  0.  Hickey 

1977.  Elk-snow  habitat  relationships  in  the  Pete  King  Drainage,  Idaho.  Bull, 
No.  6.   23  p.   Idaho  Dept.  Fish  and  Game,  Boise. 

Lyon,  J.  L. 

1979.  Habitat  effectiveness  for  elk  as  influenced  by  roads  and  cover.  Jour. 
For.  77(10) :658-660. 

Mandel,  R.  D.  and  D.  W.  Kitchen 

1979.   The  ecology  of  Roosevelt  elk  in  and  around  Redwood  National  Park.   69  p. 
Park  Contract  PX8480-8-0045.   Humbolt  State  Univ.,  Areata,  Calif. 

Marcum,  C.  L. 

1976.  Habitat  selection  and  use  during  summer  and  fall  months  by  a  western 
Montana  elk  herd.   _In  Proceedings  of  the  elk-logging-roads  symposium,  p.  91-96. 
Univ.  Idaho,  Moscow. 


Martinka,  C.  J. 

1976.  Fire  and  elk  in  Glacier  National  Park.  In  Proceedings  tall  timbers 
fire  ecology  conf.  No.  14:377-389. 

Maurer,  B.  A.,  L.  B.  McArthur,  and  R.  C.  Whitmore 

1981.  Effects  of  logging  on  guild  structure  of  a  forest  bird  community  in 
West  Virginia.   Amer.  Birds  35(1):11-13. 

Pedersen,  R.  J. 

1976.   Pre-logging  elk  habitat  use.   In  Proceedings  of  the  elk-logging-roads 
symposium,  p.  85-87.   Univ.  Idaho,  Moscow. 

Pedersen,  R.  J.,  A.  W.  Adams,  and  J.  Skovlin 

1979.   Elk  management  in  Blue  Mountain  habitats.   Report,  Research  and  Develop- 
ment Section,  ODFW.   27  p.   Portland,  Oreg. 

Pedersen,  R.  J. 

1979a.   Northeast  Oregon  elk  research.   Oreg.  Wildl.  34(11) :3-5. 

Pedersen,  R.  J. 

1979b.  Management  and  impacts  of  roads  in  relation  to  elk  populations.  In 
Recreational  impact  on  wildlands:  Proceedings  of  a  conference,  p.  169-173. 
USDA  For.  Serv.,  Pac.  Northwest  Reg.,  Portland,  Oreg. 

Perry,  C.  and  R.  Overly 

1976.  Impact  of  roads  on  big  game  distribution  in  portions  of  the  Blue  Mountains 
of  Washington.   Jto   Proceedings  of  the  elk-logging-roads  symposium,  p.  62-68. 
Univ.  Idaho,  Moscow. 

Reynolds,  H.  G. 

1962.   Effect  of  logging  on  understory  vegetation  and  deer  use  in  a  ponderosa 
pine  forest  of  Arizona.   USDA  For.  Serv.  Res.  Note  RM-64.   3  p.   Rocky  Mt.  For. 
and  Range  Exp.  Sta. ,  Fort  Collins,  Colo. 

Schoen,  J.  W. 

1977.  The  ecological  distribution  and  biology  of  wapiti  (Cervus  elaphus  nelsoni) 
in  the  Cedar  River  Watershed,  Washington.   Ph.D.  Thesis.   406  p.   Univ.  Wash., 
Seattle. 

Smithey,  D.  A.,  M.  J.  Wisdom,  and  W.  H.  Hines 

1982.  Roosevelt  elk  and  black-tailed  deer  response  to  habitat  changes  related 
to  old-growth  conversion  in  south  western  Oregon.  Northwest  Sec.  Wildlife  Soc. 
Paper,  presented  in  symposium  on  wildlife  relationships  in  old-growth  forests. 
Juneau,  Alaska. 

Swanson,  D.  0. 

1970.   Roosevelt  elk-forestry  relationships  in  the  Douglas-fir  region  of  the 
Southern  Oregon  Coast  Range.   Ph.D.  Thesis.   173  p.   Univ.  Mich.,  Ann  Arbor. 

Szaro,  R.  C.  and  R.  P.  Balda 

1979.   Effects  of  harvesting  ponderosa  pine  on  nongame  bird  populations.   USDA 

For.  Serv.  Res.  Pap.  RM-212.   8  p.   Rocky  Mt.  For.  and  Range  Exp.  Stn. ,  Fort  Collins, 

Colo. 


status  review.   USDI,  FWS ,  Endangered  Species 


U.S.  7ish  and  Wildlife  Service 
1982.   The  northern  spotted  owl: 
Program.   29  p.   Portland,  Oreg. 

Ward,  a.  L. 

1976.  Elk  behavior  in  relation  to  timber  harvest  operations  and  traffic  on  the 
Medicine  Bow  Range  in  south-central  Wyoming.   In  Proceedings  of  the  elk-logging- 
roads  symposium,  p.  32-43.   Univ.  Idaho,  Moscow. 

Webb,  W.  L.,  D.  F.  Brehrend,  and  B.  Saisorn 

1977.  Effect  of  logging  on  songbird  populations  in  a  northern  hardwood  forest 
Wildl.  Mono.  No.  55.   34  p.   The  Wildl.  Soc. 


Mason,  Bruce  &   Girard.  Inc. 
Consulting  Foresters 


and, Oregon  97305 


August  20,  1982 


Mr.  Robert  E.  Ragon 
Vice  President 
Sun  Studs,  Inc. 
P.  O.  Box  1127 
Roseburg,  Oregon  97  470 

Dear  Mr.  Ragon: 

This  is  our  review  of  the  Roseburg  Timber  Management  Draft 
Environmental  Impact  Statement.   It  contains  our  analysis  based 
on  your  request  to  examine  the  relative  economic  efficiency  of 
specific  alternatives  and  possible  intensive  management  funding 
problems  the  BLM  might  face  when  implementing  its  preferred  alter- 
native. 

We  believe  this  draft  environmental  statement  shows  con- 
siderable improvement  over  other  BLM  environmental  statements 
we  have  reviewed.   The  BLM  staff  at  Roseburg  was  very  helpful 
in  providing  useful  information  and  answering  our  requests.   If 
you  wish  we  will  be  willing  to  answer  any  questions  or  clarify 
any  points  for  the  BLM  about  our  analysis. 


68  17 


Summary  and  Recommendations 

1.   Current  low  timber  sale  contract  prices  and  delays  in 
harvest  due  to  depressed  wood  products  markets  indicate  the  BWs 
forecasted  revenues  in  1984,  1985  and  1986  are  too  high.   Pro- 
jected management  costs  may  exceed  25  percent  of  such  reduced 


126 


Mr.  Robert  E.  Ragon 

AuqUiit-  20, 

Page  2 

luction  in 

5  which  support  the  hi         el  of 
cut . 

unmendation  -  The  BLM  should  carefully  potenl  Lai 

i  1  be  aware  of  potent  i 
problems.   Selection  of  Alternative  2  would  alleviate  this 
possible  problem  by  maintaining  a  larger  land  base. 

2.  A  comparison  of  first  decade  management  costs  between 
Alternatives  2,  4  and  5  show  that  the  costs  per  MBF  of  harvest 
are  lowest  for  Alternative  2 .   Also,  we  show  that  intens ive 
forest  management  costs  are  a  small  percentage  of  the  total 
budget.   A  small  change  in  the  funding  level  could  substantially 
impact  the  intensive  management  program.   Under  the  preferred 
Alternative  4  such  a  reduction  could  cause  the  harvest  level  to 
fall  below  recent  past  levels.   This  is  not  true  for  Alternative 
2. 

Recommendation  -  Select  Alternative  2 . 

3.  The  benefit/cost  ratio  of  first  decade  management  is 
higher  for  Alternative  2  than  Alternative  4.   The  effects  of 
intensive  management  are  highly  significant .   Without  intensive 
management  the  Alternative  2  benefit /cost  ratio  would  drop  from 
8.5  to  1  to  6.3  to  1.   The  intensive  management  program  in  Alter- 
native 2  results  in  an  increased  annual  allowable  harvest  of  89 
million  board  feet.   This  would  generate  an  additional  $175 
million  in  the  first  decade  on  an  expenditure  of  about  $6.6 


68-18 


Mr .  Robert  E.  Ragon 
August  20,  1982 
Page  3 

Lon.   if  funding  for 
an  additional  176,000  acres  of  naturally  grown  forest  wouli 
needed  to  sustain  the  same  harvest. 

Recommendation  -  The  intensive  management  program 
critical  part  of  any  management  program  on  the  Roseburg  District 
and  the  funding  necessary  for  implementation  should  receive 
first  priority. 

4.  The  costs  per  acre  for  reforestation  reported  by  the 
Roseburg  District  are  significantly  higher  than  those  of  other 
land  managers  in  the  area.   Other  costs  per  acre  of  management 
practices  are  more  in  line. 

Recommendation  -  The  Roseburg  District  should  institute  a 
program  aimed  at  cost  reductions  on  all  reforestation  activities. 

5.  The  land  base  is  very  important  as  a  basis  for  sustained 
increases  in  harvest  levels  on  the  Roseburg  District.   Lands 
proposed  for  management  under  an  extended  rotation  must  have  5 
times  more  area  to  support  a  one  million  board  foot  annual  harvest 
level  than  under  an  intensive  management  regime.   We  recommend  that 
the  BLM  should  use  other  means  than  extended  rotations  or  use 
rotations  shorter  than  250  years  in  order  to  provide  for  other 
resource  values . 

6.  The  Soil  Expectation  Values  {SEVJ  contained  in  the 
environmental  statement  were  not  used  in  selecting  management 
regimes,  or  if  they  were,  other  unstated  criteria  were  controlling 
selections.   Also,  we  question  some  of  the  methods  used  and  are 
concerned  about  the  implications  of  the  low  and  negative  values. 


68  19 


68  20 


Mr .  Robert  E .  Ragon 
August  20,  1982 
Page  4 


Recommendation  -  The  BLM  should  reexamine  the  purpose  and 
usefulness  of  SEV's  in  preparing  the  plan  and  limit  their  pre- 
sentation in  the  EIS  to  a  few  critical  values  or  regimes  as  they 
relate  to  the  final  selection  of  management  regimes.   SEV's  should 
be  determined  with  a  4  percent  discount  rate  which  gives  greater 
weight  to  more  distant  values  and  costs,  thus  reflecting  govern- 
ment ' s  concern  for  future  generations . 

Financing  Intensive  Management 

There  is  a  critical  relationship  between  forecasted  timber 
revenue  and  estimated  timber  management  budgets  on  these  O  &  C 
lands.   Management  on  O  (,    C  lands  is  traditionally  financed  from 
a  share  of  the  stumpage  receipts.   Furthermore,  current  federal 
budget  deficits  are  forcing  agencies  to  place  greater  emphasis 
on  the  efficiency  of  alternative  investments  in  order  to  justify 
expenditures  regardless  of  source  of  funds.   This  situation  is 
further  complicated  by  the  fact  that  current  timber  sale  con- 
tracts are  not  being  logged  in  a  timely  fashion  due  to  the  de- 
pressed markets,  and  some  may  not  be  logged  or  will  be  extended. 

Because  of  this  critical  relationship  we  are  concerned  about 
preferred  alternative  which  relies  on  intensive  management 
expenditures  for  maintenance  of  a  high  level  of  harvest  volume. 
Tabic  B-2  on  page  116  of  the  DEIS  significantly  overstates  both 
the  revenue  and  cost  levels  that  can  be  expected  during  the  next 
10  years.   First,  the  forecast  revenues  for  1984  through  1987 
appear  to  us  to  be  too  high.   If  one  assumes  an  approximate  3 
year  lag  between  timber  sale  date  and  the  harvest  date,  the  har- 

Mason   Bruce  ft  Gm*»o   Inc 


68  20 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  5 

st  values  of  $302  per  MBF  during  1984  are  far  too  high.   The 
erage  price  of  timber  sold  on  the  Roseburg  District  in  1981 
was  $259  per  MBF  and  to  date  in  1982  the  average  price  is  $130 
per  MBF.   These  are  the  sales  that  will  be  cut  and  paid  for 
during  1983  and  1984. 

Also,  the  harvest  levels  shown  in  Table  B-2  overstate  what 
reasonably  could  be  expected  to  be  harvested  during  1984  to  1986. 
The  BLM  will  not  begin  to  sell  its  higher  proposed  allowable 
harvest  volume  until  1984.   Consequently,  none  of  this  increased 
volume  will  be  harvested  until  about  1987. 

The  estimated  forest  management  costs  shown  in  Table  B-2 
do  not  adequately  reflect  the  actual  acres  that  are  to  be  treated 
in  the  initial  part  of  the  decade.   In  particular,  the  increased 
planting  acreage  shown  by  BLM  will  not  be  necessary  until  some- 
time after  1987  when  the  increased  harvested  areas  actually  are 
ready  for  planting. 

We  have  made  a  revised  estimate  of  sales  volume  and  projected 
revenues  and  costs  in  Exhibit  1.   In  our  opinion  these  are  more 
realistic  estimates  of  the  sales  volumes  and  values  to  be  expected 
during  the  next  3  years.   Exhibit  1  also  includes  an  estimate  of 
actual  harvest  levels  for  1982-84  and  two  levels  of  estimated 
harvest  values  per  KBF  for  1984-86.   Based  on  these  estimates 
it  is  our  opinion  there  is  a  possibility  that  25  percent  of  the 
receipts  from  timber  harvest  would  not  be  sufficient  to  fund 
the  estimated  forest  management  costs  shown  in  the  BLM  Table  B-2. 


68  21 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  6 


As  a  result  we  recommend  that  the  BLM  more  closely  evaluate 
potential  income  flows  against  estimated  costs.   Final  plans 
should  provide  for  such  a  contingency  in  order  to  insure  a  con- 
tinued high  level  of  annual  timber  harvest. 

Economic  Efficiency  of  Alternatives 

Forest  management  costs  should  be  carefully  examined  in 
relation  to  the  benefits  in  terms  of  harvest  volumes  produced. 
The  BLM  planning  does  not  clearly  present  this  relationship  for 
each  alternative.   We  have  displayed  the  first  decade  costs  for 
forest  management  for  three  of  BLM's  alternatives  in  our  Exhibit  2. 
The  bottom  line  reveals  that  the  management  costs  per  MBF  pro- 
duced by  Alternatives  2  and  4  are  6  percent  less  than  those  of 
Alternative  5.   Alternative  2  has  the  lowest  per  MBF  cost  and 
by  that  criteria  would  be  the  best.   Exhibit  2  also  shows  that 
the  major  expenditures  in  Alternatives  2,  4  and  5  (other  alter- 
natives are  similar)  are  for  planting,  replanting  and  sale  preparation 
and  administration.   These  are  basic  activities  and  do  not  include 
the  intensive  management  costs  of  precommercial  thinning,  genetics, 
fertilization,  etc.   In  Alternatives  2  and  4,  ninety  percent  of 
the  total  management  expenditures  occur  in  these  basic  activities. 
In  contrast,  97  percent  of  the  total  management  expenditures  in 
Alternative  5  (the  present  situation)  are  related  to  planting, 
replanting  and  timber  sale  preparation  and  administration.   The 
intensive  forest  practices  proposed  in  either  Alternative  2  or 
4  make  up  the  balance  of  the  total  costs,  or  about  10  percent. 


127 

Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  7 

This  is  a  small  percent  of  the  total  manag  ires 

required.   Yet,  these  expenditures  will  generate  a  very  substai 
increase  in  the  allowable  harvest  r 

Economic  Efficiency  of  Intensive  Practices 

Total  costs  and  total  revenues  cannot  be  used  alone  to  compare 
the  relative  efficiency  of  alternative  plans  nor  of  forestry  prac- 
tices within  plans.   We  have  examined  ncy  using 
benefit/cost  ratios  for  only  the  first  decade  and  have  isolated 
intensive  management  effects  on  the  ratios.   In  a  comparison  of 
Alternative  2  and  the  BLM  preferred  Alternative  4,  we  found  tl 
Alternative  2  had  the  highest  benefit  to  cost  ratio.   (See  Exh 
3. )   Alternative  2  provides  about  $526  million  in  disco 
decade  revenue  against  discounted  costs  of  $61  mil!. 
ratio  of  8.5  to  1.   The  BLM's  preferred  alternative  would  pro- 
duce about  $490  million  in  discounted  first  decade  reve; 
discounted  costs  of  $58  million  and  a  ratio  of  8.4  to  1. 

In  order  to  measure  the  effects  of  intensive  management, 
examined  Alternative  2  under  the  assumption  that  funds  mi 
not  be  available  in  the  first  decade  to  implement  the  planned 
intensive  forest  management  practices .   These  practices  included 
genetic  planting,  precommercial  and  commercial  thinning  and  ferti- 
lization.  These  practices  require  only  about  10  percent  of  the 
expected  first  decade  costs  in  Alternative  2.   But  reduced  stumpage 
revenue  early  in  the  decade  is  a  possibility  as  noted  earlier. 
If  this  should  happen,  a  likely  candidate  for  cost  savings  would 
be  the  intensive  practices.   However ,  we  would  not  recommend  such 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  8 

action  because  of  the  critical  and  highly  productive  responses 
to  intensive  management  in  terms  of  increased  harvest .   Our 
analysis  results  in  Exhibit  3  shows  the  impact  of  intensive 
practices.   Without  these  the  benefit/cost  ratio  for  the  first 
decade  in  Alternative  2   is  reduced  from  8.5  to  1  down  to  6 . 3 
to  1 .   A  similar  reduction  could  be  expected  without  the  intensive 
practices  in  BLM's  preferred  Alternative  4. 

The  great  importance  of  the  intensive  management  funding 
is  further  illustrated  in  Exhibit  4.   The  annual  harvest  of 
Alternative  2  is  increased  by  8  9  million  board  feet  because  of 
intensive  management.   The  benefit/cost  ratio  of  the  first  decade 
intensive  management  program  is  26.3  to  1. 

The  impacts  of  the  intensive  management  program  on  the 
harvest  level  (often  called  the  allowable  cut  effect)  was 
estimated  because  time  did  not  permit  use  of  BLM's  SIMIX  model. 
We  considered  only  the  first  decade  harvest  impacts  as  shown 
in  Exhibit  4.   The  total  first  decade  harvest  increase  due  to 
an  intensive  management  program  was  allocated  to  the  several 
practices  in  proportion  to  the  effects  of  those  practices  on 
per  acre  yields  in  a  fully  regulated  forest  over  a  rotation. 

The  genetic  planting  program  produces  the  largest  impact 
during  the  first  decade.   An  additional  28.4  million  board  feet 
in  first  decade  annual  harvest  can  be  attributed  to  planting 
1,520  acres  with  genetically  improved  stock.   The  combined  pre- 
commercial and  commercial  thinnings  provide  the  next  best  invest- 
ment opportunity. 

Mason  Bftucc  a  Giaaho  Inc 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  9 


The  selection  of  a  plan  alternative  should  consider  the 
DO~22  effects  of  possible  short  falls  in  funding  of  the  planned  manage- 
ment practices.   We  have  estimated  that  a  reduction  of  only  about 
$3  million  in  intensive  funding  after  such  a  plan  v. 
would  reduce  the  harvest  under  the  preferred  alternative  to  below 
the  current  harvest  level  of  201  million  B.F.   However,  under 
Alternative  2  such  a  reduction  in  funding  would  reduce  the  har- 
vest to  about  224  million  board  feet  or  about  the  recent  past 
level.   We  conclude  from  this  that  Alternative  2  is  a  much 
better  alternative  for  implementation  because  it  contains  a 
base  that  is  large  enough  to  provide  better  assurance  c 
timber  supplies.   To  illustrate  this  we  calculated  the  ■ 
land  area  (under  natural  growth)  that  would  be  needed  to  replace 
the  allowable  harvest  lost  due  to  lack  of  funds  for  the  inten- 
sive management  program.   (See  bottom  of  Exhibit  4. 
estimate  that  over  176,000  acres  of  unmanaged  forest  land  wc 
be  needed  to  replace  the  89  million  board  feet  harvest  volume 
attributable  to  intensive  managemei 

Cost  Efficiencies  for  Individual  Intensive  Practices 

Reforestation  and  replanting  costs  on  the  Roseburg  District 
are  a  substantial  part  of  the  forest  management  bu.  have 

noted  above.   Our  examination  reveals  that  these  arc  also  high 
on  a  per  acre  basis.   Therefore,  in  terms  of  improving  efficiency, 
this  cost  bears  closer  examination  as  a  possible  target  for  cost 
reduction  efforts.   We  have  reviewed  planting  costs  for  other 
agencies  and  industry  and  show  the  results  in  Exhibit  6.   As  a 


128 


68  23 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  10 


concern  ovei 
cost  reported  in  the  DEIS  for  the  Roscburg  District.   Foi 
two  local  national  fori  State  of  Oregon  and  forest  industry, 

planting  costs  arc  significantly  lower  than  the  Roscburg  Di 
The  costs  reported  for  chemica 1  release,  precommercial  thinning 
and  fertilization  on  the  Roseburg  District  seem  to  be  more  in 
line  with  those  of  the  other  land  managers.   It  should  be  noted 
that  reforestation  expenditures  are  made  in  the  first  few  years 
of  a  rotation  and  therefore  significantly  affect  the  soil 
expectation  values  (SEV)  shown  in  the  DEIS.   We  will  have  more 
to  say  about  this  lat. 

Our  concern  here  is  with  the  need  for  an  effort  to  reduce 
BLM  regeneration  costs.   It  is  our  recommendation  that  BLM  should 
include  in  their  plan  provision  for  specific  regeneration  cost 
reduction  efforts  during  the  plan  decade.   Such  reductions  would 
better  assure  that  management  funding  from  25  percent  of  receipts 
would  be  adequate  in  the  future-. 

Effects  and  Costs  of  Extended  Rotations 

The  extended  rotations  used  to  provide  for  other  resource 
values  have  a  substantial  impact  on  the  allowable  harvest  of  the 
District.   We  believe  that  BLM  has  not  properly  informed  the 
DEIS  public  reviewers  of  the  highly  significant  impact  of  reserving 
areas  for  management  under  extended  rotations  of  250  years  without 
intensive  management.   Our  calculations  indicate  that  this  manage- 
ment will  use  five  times  as  much  area  to  produce  a  given  volume 
of  annual  harvest  as  the  area  needed  under  intensive  management . 

Mason   Bruce  ft  G.waro   Inc 


Mr.  i  i  -igon 

August  20,  1982 


In  I 
needed  to  produce  one  million  board  ft_-el  of  al 
harvest  under  intensive  managemei 

of  250  years.   The  capitalized  annual  costs  of  management  only 
{without  capital  cost  of  the  land  and  growing  stock  i 
$633,900  for  the  1,018  acres  of  intensively  managed  lands  and 
$450,700  for  the  5,020  acres  of  extended  rotation  lands, 
indicates  that  the  management  cost  of  producing  one  million  board 
feet  under  an  extended  rotation  is  lowest.   However,  one  must 
evaluate  the  cost  of  the  necessary  extra  area  of  4,002  act 
the  regulated  growing  stock  on  that  area.   The  average  acre  under 
a  regulated  condition  with  a  250  year  rotation  would  contain  a 
stand  125  years  of  age.   In  our  opinion  such  lands  would 
a  cost  value,  if  obtained  in  the  Roseburg  area,  of  at  least 
$5,000  per  acre.   Thus,  we  sec  that  an  extra  capital  cost  of 
$20,000,000  for  the  extra  4,002  acres  would  be  required  in 
addition  to  the  capitalized  management  cost  of  $450,700  in  order 
to  produce  one  million  board  feet  annually.   This  illustrates 
the  exorbitant  cost  of  timber  output  from  extended  rotations. 
All  possible  effort  should  be  made  by  BLM  to  use  other  means 
or  much  shorter  extended  rotations  to  provide  the  other  resource 
values. 

Significance  and  Reliability  of  Soil 
Expectation  Values  in  Choosing  an  Alternative 

The  soil  expectation  values  (SEV)  contained  in  the  DEIS 

are  the  result  of  a  new  analysis  on  the  part  of  the  BLM.   We 


68  24 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  12 


agree  that  detailed  economic  analysis  is  needed  to  help  determine 
the  most  efficient  timber  producing  regime .   However ,  we  are 
concerned  about  the  methods  used  and  the  impl ications  of  the 
SEV  calculations. 

First  of  all,  we  have  not  observed  the  use  of  economic 
efficiency  as  a  guide  to  planning  by  the  BLM  in  past  years .   In 
fact,  many  of  its  management  policies  such  as  even  flow  of  har- 
vest volume  and  the  goal  of  regeneration  within  a  5  year  period 
fail  to  measure  up  under  any  economic  efficiency  criteria .   Also 
we  note  that  the  most  efficient  combination  of  management  techniques 
shown  in  the  DEIS  are  under  a  65  year  rotation  for  a  managed 
stand,  yet  this  was  not  selected. 

It  seems  obvious  to  us  that  SEV's  were  not  used  by  BLM  in 
developing  the  most  efficient  management  prescription .   While 
we  believe  these  should  have  been  used  as  guides,  we  are  con- 
cerned that  the  BLM  calculations  over  state  costs  and  are  not 
entirely  reliable.   Also,  the  presentation  of  many  negative  values 
is  misleading. 

A  major  factor  in  determining  the  level  of  the  BLM  values 
is  the  high  regeneration  costs  in  the  first  years  of  a  rotation. 
This  causes  most  of  the  low  or  negative  indicated  values.   In 
western  Oregon  millions  of  acres  are  being  managed  on  a  sustained 
yield  basis  which  implies  that  other  land  owners/managers  are 
more  cost  efficient,  or  have  different  outlooks  for  future  revenues, 
or  require  less  return  on  forestry  investments . 


6825 


Mr.  Robert  E.  Ragon 
August  20,  1982 

Page  1  3 

Our  examination  indicates  the  treatment  of  administrative 
costs  by  BLM  in  their  SEV  calculations  was  incorrect.   Apparently, 
these  have  been  handled  this  way  because  of  the  accounting  or 
budgetary  procedures  used  within  the  agency.   These  tend  to  be 
the  same  regardless  of  the  alternative  and  thus  they  could  have 
been  excluded  since  the  SEV's  were  only  for  comparative  purposes. 

We  are  also  concerned  that  a  portion  of  the  administrative 
costs  are  such  items  as  planning  or  wildlife  management.   These 
produce  other  multiple  resource  values  which  are  generally  not 
to  be  included  in  the  SEV  calculations  used  to  evaluate  timber 
production  efficiency. 

The  SEV  calculations  should  use  a  discount  rate  that  reflects 
real  rate  of  return  appropriate  for  the  federal  government.   The 
U.  S.  Forest  Service  recently  conducted  a  detailed  study  about 
appropriate  discount  rates  and  came  to  the  conclusion  that  4 
percent  was  an  acceptable  real  rate  of  return  for  government  use 
in  planning.   We  concur. 

We  believe  that  the  BLM  assumptions  about  future  price 
increases  for  forest  products  are  realistic.   The  BLM  may  have 
used  an  initial  price  level  that  was  too  high.   However,  a  lower 
initial  price  per  MBF  would  not  likely  change  the  SEV's  cal- 
culated because  the  revenues  are  in  the  distant  future. 

Regarding  SEV's  our  recommendation  would  be  that  the  BLM 
reexamine  their  purpose  and  usefulness  in  preparing  the  plan 
and  to  limit  their  presentation  in  the  EIS  to  only  a  few  critical 
values  as  they  relate  to  the  final  selection  of  management  regimes. 


Mason   Bmuct  ft  Gi»*wo  Iwc 


129 


Mr.  Robert  E.  Ragon 
August  20,  1982 
Page  14 


These  values  should  be  determined  with  a  4 

which  gives  greater  weight  to  more  distant  values  and  costs,  thus 

reflecting  government's  concern  for  future  generations. 

We  would  be  pleased  to  discuss  any  of  our  findings  or 
recommendations  with  you  or  members  of  the  Roseburg  District 
staff  in  del  i 
Sincere  ly , 


Carl  A.  Newport 
David  R.  Cox     / 


CAN:DRC:  jlf 
Attachments 


EXHIBIT  1 
ESTIMATED  SALES,  HARVEST  RATES  AND  PROJECTED  REV 
ON  ROSEBURG  DISTRICT,  BI,M 
IN  FY  1984,  1985  AND  1986 


FY  Year 

1981 

1982  (est.) 

1983  (est.) 

1984  (est.) 


1984 
1985 
1986 


Estimated 

Sales 

MBF 

182,900 

185,000 

200,000 

246,000 


Harvest  Harvest 

Level    Value 

MBF      $/MBF 

150,800    $322 


Aver 
Sales  Value 
5/MBF 

$259.81 

150.00 

180.00 

216.00 


Optimistic  Value  Level 

185,000  260 
190,000  150 
200,000     180 


O  S,  C  25% 

Funding  From 
Estimated  Harvest 
i  on  $ 

12.1 


12.025 
7.125 
9.000 


Pessimistic  Value  Level 


1984 

1985 
1986 


185,000  200 
190,000  130 
200,000     150 


9.250 
6.175 
7.500 


EXHIBIT  2 

COMPARISON  OF  FIRST  DECADE 

ESTIMATED  FOREST  MANAGEMENT  COSTS 

FOR  ALTERNATIVES  2,  4  &  5 

ROSEBURG  DISTRICT  -  BLM 


.1/ 


EXHIBIT  3 
NET  PRESENT  VALUE  OF  FUTURE  REVENUES  AND  COSTS- 
FOR  PLAN  ALTERNATIVES  2,  4  AND  2 (WITHOUT  INTENSIVE  MANAGEMENT) 
DURING  THE  FIRST  DECADE  OF  EACH  PL 


Present  Value   Present  Value 


Alternative 


Total  Decade  Costs- 
Total  Planting  and 
Replanting  Costs 

Planting  and  Replanting 
Cost  as  a  Percent  of 
Total  Costs 


$75,218,600   $70,543,400   $60,480,200 
33,820,800    31,640,600    23,883,800 


45%  45%  39% 

Sale  Preparation  and  Admin.    33,689,400    31,477,300    35,299,200 


Sale  Preparation  and  Admin. 

as  a  Percent  of  Total  Costs      45% 


45% 


Total  Cost  per  Thousand 
Board  Feet  Produced 


$28.17        $28.33 


581 


$30.10 


1st  Decade 

1st  Decade 

Be 

nef it/Cost 

Alternative 

Revenues 

Costs 

Ratio 

M$ 

M$ 

4  (BLM  preferred) 

$491,185 

$57,981 

8.4:1 

2 

526,101 

61,824 

8.5:1 

2  w/o  intensive  mgmt . 

350,576 

55,162 

6.3:1 

1/ 


Revenue  and  costs  discounted  at  4  percent  from  the  midpoint 
of  the  decade.   Costs  (those  shown  in  DEIS  on  page  121)  were 
increased  at  0.42%  and  revenues  at  1.65%  real  rates  to  the 
midpoint  of  the  decade. 


-   Includes  costs  shown  in  BLM,  Roseburg  DEIS  on  page  121.   Costs 
are  not  discounted. 


130 


COST  NATIVE  2 

ROSEBURG  DISTRICT  -  BLM 


IN  OP  AREA 
NEEDED  TO  PRODI1 
ANNUAL  HARVEST  UNDER  INTENSIVE  AND  EX 
ROSEBURG  DISTRICT  -  BLM 


visive 
:  ml     Ln  ai  t  ei  rial  Lve   2 

Value   of    Increased  Annual 
I    During    Firs!    Decade   due  to 

Value   of    the   Annual    Costs 
t    Practices 
During   First   Dot. 

Ratio  of    1 1 

il  ed  ai  lowable  Cut  El 
g  First  Decade  For: 


89,280  MBF 


5175,525,000 


$6,662,000 


Intensive 
I  ice 


Extra      Acres  to     Extra  Annual 
Annual     be  Treated     Harvest  per  Cost  per  Acre 
Harvest    During  Decade   Acre  Treated     Treated 


Planting   28.1  MMBF 

i  on      19.6  MMBF 

CT  37.5  MMBF 


1,520 
57,984 
42,240 


18.490  MBF 
0.338  MBF 
0.888  MBF 


10 
72 
90 


Acres  Needed  to  Provide  One 

on  Board  Feet  (B.F.)  of 
Sustained  Yield  Harve 

Acres  Harvested  Each  Year  to 
Provide  One  Million  B.F. 

Total  Capitalized  Cost  of 
Management  Expenditures  to 
Produce  One  Million  B.F. 
Indefinitely  (4%  Rate) 

Additional  Acres  Needed  to 
Produce  One  Million  Board 
Feet  Under  Extended  Rotation 

Estimated  Cost  of  Additional 
Land  and  Growing  Stock  Needed 
Under  Extended  Rotation  at 
$5,000  per  acre. 


ment    Ro- 
Regime 


1,018  ^c.  5,020  ac. 

12.89  ac.      20.08  ac . 


$633,900 


4,002  ac. 


$20,000,000 


85, 140  MBF 


Additional  Acres  of  Naturally 

Grown  Forest  Land  Needed  to 

Replace  and  Sustain  the  Same 

Amount  of  Annual  Harvest  (85,140  MBF) 

as  is  Obtained  by  Intensive  Management 


176,400  acres 


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Response  to  comments  in  Letter  68. 

68-1         See  response  to  comment  4-1. 

68-2         The  70,000  acres  of  old  growth  remaining  under  Alternative  7  after 
ten  decades  of  management  is  the  result,    for  the  most  part,  of  a 
large  acreage  withdrawal   because  of  reforestation  problems.  The  lands 
would  occur  as  small  tracts  not  properly  distributed  to  provide 
habitat  for  the  identified  spotted  owls. 

On  the  other  hand,  contained  within  the  68,100  acres  of  old  growth 
remaining  under  Alternative  6  are  acres  specifically  earmarked  and 
arranged  around  the  identified  owls  so  as  to  meet  their  habitat 
needs. 

68-3         See  response  to  comment  11-8. 

68-4         The  Oregon  Endangered  Species  Task  force  management  recommendations 
and  the  proposed  revision  of  the  Oregon  Interagency  Spotted  Owl 
Management  Plan  provided  a  basis  for  EIS  analysis,  not  a  specific 
proposal   for  implementation. 

68-5         The  DEIS  was  in  error.  The  text  has  been  revised   in  the  FEIS,  Chapter 
3,  Vegetation  Conclusions  section. 


131 


68-6         The  Glossary  definition  has  been  corrected. 

68-7         The  methodology  utilized  to  determine  elk  population  response  to 
varying  habitat  conditions  in  the  Tyee  area  provided  for  the 
classification  of  forest  stands  in  excess  of  120  years  of  age  as 
survival   cover.  Additionally,   stands  45-120  years  of  age  were 
assumed  to  provide  summer  and  winter  thermal   cover  needs.  Refer  to 
DEIS,  Chapter  2,  Affected  Environment,   page  45. 

68-8         Forest  stands  50-120  years  of  age  meet  thermal   cover  needs.  Stands 

120  years  of  age  and  older  supply  both  the  food  resources  and  thermal 
qualities  viewed  as  important  for  survival  during  severe  winter 
weather  periods.  The  age  class  spread  represents  a  range  of  quality 
in  relation  to  cover,  with  the  older  stand  providing  better  quality 
survival   cover  and  being  capable  of  better  serving  the  overall  needs 
of  the  animals. 

68-9         As  stated  in  the  EIS,  Chapter  3,  Table  3-11,   the  elk  populations  are 
predicted  to  decline  20  percent  below  present  levels  after  five 
decades  in  response  to  the  changes  in  habitat  (cover- forage)   brought 
about  by  intensive  forest  management  practices  on  the  habitat  they 
occupy.   Elk  would  continue  to  exist.  Simply  stated,   the  habitat 
quality  which  exists  today  is  thought  to  be  capable  of  supporting  a 
larger  population  of  elk  than  that  which  will  be  a  product  of  five 
more  decades  of  intensive  forest  management. 

68-10       The  18  pairs  of  spotted  owls  projected  to  remain  in  Alternatives  3 
and  4  represent  a  67  percent  decline  from  existing  conditions.  This 
decline  in  owl  pairs  comes  as  a  result  of  reducing 


the  old  growth  base  by  appro* 
relationship,   it  can  be  stated  thai    the  ow] 
indicator  of  chan-j 

68-11       The  text  has  been  revised    in  the  PEIS,  Chapter   "i,    Impai 

Transportation  System  in  Terrestrial  Vert  '  .on. 

68-12       The  text  has  been  revised   in  the  FEIS,  Chapl  ts  on  Animals, 

Other  Timber  Management  Treatments  section,  del* 
statement  on  slash  burning. 

68-13       Western  Oregon  biologists  have  noted  slash   from  pre-comm 

thinning  lasting  1-2  decades.  Approximately  30,000-40,000  acres  would 
be  treated  in  the  first  decade,  representing  about  10  percent  of  the 
SYU  acreage  and  a  significant  loss  of  habitat. 

68-14       It  may  be  that  shelterwood  and  seed  tree  harvest  provide  adeq 
forage;   however,   commercial   thinning  as  practiced   in  the  Ro.v 
District  creates  neither  prime  forage  nor  cover.   Compared  with  old 
growth  habitat  interspersed  with  clearcuts,  quality  of  thinned  areas 
as  elk  habitat  is  considerably  less. 

68-15       The  text  has  been  revised  in  the  FEIS,  Chapter  3,   Impacts  on  Animals, 
Fish  Conclusions  section.  Temperature  has  been  removed   from  the 
discussion.  See  response  to  comment  16-18   for  discussion  on  9 

68-16       The  text  has  been  revised   in  the  FEIS,  Chapter  3,   Impacts  on  Animals, 
Terrestrial  Vertebrates,  Timber  Harvest  section. 


68-17       See  text  revision,  FEIS,  Appendix  3,  Table  B-2. 

68-18       See  response  to  common  issue  5. 

68-19       As  noted  on  page  114  of  the  DEIS,   an  analysis  of  the  economic 
efficiency  of  the  forest  management  practices  in  the  Original 
Proposed  Action  was  requested  by  members  of  the  public  during  the  EIS 
scoping  process.  Soil  expectation  value  was  the  method  of  evaluation 
requested.  Soil   expectation  value   is  not  a  variable  listed   in  either 
the  original  district  planning  criteria  (Appendix  C)  or  the  O&C 
Forest  Resources  Policy  (Appendix  A)   to  be  used   in  developing  plans 
for  BUA  administered  forest  lands  in  western  Oregon. 

68-20       Table  B-2  has  been  revised  to  increase  the  number  of  baselines  for 
forecasting  revenue;   however,  note  that  the  numbers  reported   in 
Tables  3-1  and  B-2  of  the  DEIS  are  decadal   averages  spread  evenly 
across  the  period  for  the  purpose  of  obtaining   a  discounted 
benefit-cost  ratio  of  the  timber  management  program  in  the  proposed 
action.  No  attempt  was  made  to  speculate  on  cyclical   ups  or  downs. 
The  1984  to  1986  harvest  level   reported  could  be  a  significant 
understatement  of  actual  harvest  if  the  economy  is  in  an  upturn  and 
the  more  than  616  MM  bd.  ft.  on  the  district  now  sold  but  uncut  were 
also  being  harvested.  In  the  case  of  increased  actual  harvest,   the 
number  of  acres  being  planted  would  also  be  greater  than  that  planned 
for  in  Table  1-2  of  the  DEIS.  Also,  see  response  to  comment  15-2. 


68-21       Neither  the  district's  planning  criteria  (Appendix  C)   nor  the  O&C 
Forest  Resources  Policy  (Appendix  A)   suggest  that  a  choice  among 
alternatives  will  be  based  on  econaru 

feasibility  was  a  factor  in  the  selection  of  intensive  management 
practices  for  all   alternatives. 

68-22       See  response  to  carutDn  issue  2. 

68-23       See  response  to  common  issue  4. 

68-24       See  response  to  comment  68-19. 

68-25       Table  B-l   includes  interdisciplinary  support   arid  review  as   a 
the  district  forest  management  program.  The  costs  of  inter- 
disciplinary support   and  review  are  in  Table  B-6 
DEIS.  The  baseline  yields,   costs  and  revenues  of  Table  B-6  in 
DEIS  are  the  determinates  of  the  analysis  of  soil   expectation  value. 


69 


132 


ASSOCIATION     OF    O&C     COUNTIES 


COWM  0*11  0  KHMOC*  Nil 
■INTO*  COUNTY  COUMTNOVU 
CORVA1LI9   OftfOON  »'»» 


COUU   UN  ' 

KM."  cowwrv  c 

0*1  LA*   ORIOONtflM 


f^f 


August    19,    1982 


PHOHI  kmtmm 

■ARROWS  COUNUL 
B1  I  *    ISVi  ftVtMJl 


Mr.  Junes  Hart,  Disc.  Mgr. 
Bureau  of  Land  Management 
777  NW  Garden  Valley  Bvld. 
Roseburg,  OR  97470 

Dear  Jim, 

On  behalf  of  the  Association  of  O&C  Counties,  the  following  response  to  the 
Roseburg  District  Bureau  of  Land  Management  Timber  Management  Draft  Environmental 
Statement  is  here-wlth  submitted. 

In  the  past,  responses  to  BLM  Draft  Statements  were  intended  and  limited  to 
their  scope  and  adequacy.  Advocacy  of  a  particular  plan  was  the  subject  of  the 
response  to  the  Final  EIS .  We  understand  that  the  process  has  now  been  changed 
where-by  the  FEIS  will,  in  effect,  become  a  Tentative  Decision  Document.  Thus 
this  response  will  not  only  critique  the  DEIS  but  it  will  also  set  forth  our  druthers. 

The  DEIS  appears  to  be  adequate  in  scope  and  is  sufficient  in  detail  on  most, 
but  not  all,  Issues.  Our  concerns  are  listed  and  discussed  in  the  following  para- 
graphs . 

COMPARATIVE  COSTS 

Nowhere  in  the  DEIS  is  there  a  table  showing  the  budgetary  requirements  of 
each  Alternative.   The  lack  of  such  data  leaves  the  responcUr   and  the  decision 
maker  in  the  dark.   Each  Alternative  is  developed  on  the  premise  that  there  will 
be  full  funding.   Past  and  present  trends  of  Congress  indicate  that  unlimited 
funds  will  probably  not  be  available.   Thus  after  a  plan  is  selected  and  implemented, 
the  annuaL  timber  sale  will  still  have  to  be  tailored  to  fit  the  available  funds. 

We  remind  that  the  days  of  easy  money  due  to  the  use  of  a  generous  25%  plow- 
back  fund  appear  to  be  over.   25%  of  projected  receipts  during  the  next  decade 
will  not  be  sufficient  to  meet  the  needs  of  Alt.  5  (the  Ejdsting),  much  less,  monies 
needed  to  carry  out  the  higher  level  of  intensive  management  called  for  in  Alt.  4, 
(the  Proposed  Action). 

We  are  not  faulting  the  District  for  proposing  a  higher  level  of  intensive 
management,  we  commend  you.   But  the  reality  of  full  funding  is  Is  doubtful,  accord- 
ingly,  the  chosen  plan  must  be  responsive  and  flexible  to  the  mode  of  each  years 
Congressional  monetary  priority.   Because  of  their  higher  timberland  base.  Alternatives 
I  and  2  will  be  more  adaptable  i:o  funding  deficiencies  than  the  other  Alternatives, 
including  the  Proposed  Action. 


Mr.  James  Hart 


Auguit  19,  1982 


We  trust  that  the  Pinal  EIS  will  contain  the  projected  cotti  of  each  rltar- 

native . 

DEPARTURE    FKOM  NON-DECLININC   EVEN-FLOW 

The   DEIS    leads   one   to   believe   that   any  departure  that    takes   the    allowable 
harvest   below  the   Long  Run  Sustained  Yield    for   any  period  of    time    is    illegal. 
This   Is   not   so   -   It    Is   simply  Bureau  policy.      Historically   the  private   timber   lands 
of   Douglas  County  have   provided   the    lion's   share  of    raw  wood   for   local  manufacturing. 
Only   in  very  recent   decades   have   the  Federal    tlaberlanda  made   any   sizable   contrib- 
ution  to   the   needed   supply.     The   result   of   this    imbalance    Is   that     private   stands 
of  harvestable   timber   are    In  short   supply  and   their  new  stands  of   regrowth 

are   a   few  decades   from  maturity. 

Table  C-l   shows   that  over  one  half  of    the   BLM  acreage    In   the  .District    is    above 
rotation  age.      This  over-abundance  of  mature   timber  compared   to   a  short   supply  of 
growing   stock   is   almost   the   exact  opposite  of  the   situation      existing  on   the   county's 
industrial   private    forest    lands.      Private   growers   are   short  on  mature   timber   and 
long  on  reprod.      It   appears   that   each   (private   and   federal)    have   what   the  other 
needs   for  a  balanced   age-class   distribution.      If   not  now,      surely  this   possibility 
of   departure   should  be  explored  prior  to   the   next   decadal   planning  exercise. 

CONSISTENCY  WITH   THE   O&C   ACT  ANT)  OTHER    LAI'D   USE    PUNS 

The  O&C  Act   specifically   stresses   the   stability  of   local   communities   as    a  major 
purpose.     The  Federal   Land  policy   and  Management  Act   states   that   the    land  use   plans 
of   the  .Secretary  "shall  be   consistent  with  State   and   local   plans   Co   the  maximum 
extent    that   he    finds   consistent  with  Federal    law  and  the   purposes  of   the  Act". 

The   DEIS    Indicates   that    the   Proposed  Action   is  not   consistant   with  the  Forestry 
Plan   for  Oregon  and  we   submit    that   the    larger   acreages  of    land   set    aside    for 
unprotected  wildlife  species   is  not    in  compliance  with  FLPMA  or   the  O&C  Act. 

FERTILIZATION 

We  note   that   the  PA      provides    for   about    56,000   acres  of   chinned   stands  to  be 
fertilized.      This    is   a  commendable   start.      However,    we   believe   that   among   the 
_     100,000+  acres  of   stands   under   Che   30  year  class   shown  on  Table  C-l,    chere   is   also 
Qy~^    an  opportunicy   for   a  fertilizer  program  on   some   unthinned   stands.     We   recommend 
that   these   acres  be   surveyed   to   determine   if   such  a  possibility  exists.      If    the 
survey  finds,    as  we  expect,    that   some  unthinned  stands  can  be  benefited,      the   plan 
should  allow  for   it's   immediate    implementation.      Lost   production   is    lost   forever. 

VISUAL   MANAGEMENT 

Because  of   the  mixed  ownership  pattern,    it   is   doubtful   that   any  BLM  visual 

I  control  will  be  of   any  meaningful   value.      We  believe  that   chat   the   BLM's  visual 
management    program  should  be    restricted    CO   only    those    areas    so    designated    as    scenic 
routes  by   the  Federal,    State  or    Local   governments. 

In  addicion  where   che   BLM's  ownership  is   incer-mixed  with  unrescricced  privace 
lands,    we   submic   chat    the   250  ya  minimum  harvesc    age   Is  much   too  high.      In  our 
detailed   analysis  of   the   Coos   District   plan,    we  concluded  that   a    120  MHA  was 
sufficient.      Under   the  Area  Control  Harvest  concept    as  proposed,    only    1.2%  of    the 
land  area  would  be   disturbed   annually  or    12%  during  the   decade. 


Mr.  James   Hart 


August    19,    1982 


MANAGEMENT   CRITERIA      AND  CRITERIA   APPLICATION 


July    11,     1982 


This  Association  put   forth  considerable   effort    and   resources   in   responding 
to   the  Co^s-Curry  EIS    .      You  have   previously  been  provided  with  a   copy  of   chac 
report.      We   are   please   to   note   that   the  Association' s  views   as   set    forth   in   that 
document  mesh  well   with   the   new  criteria   adopted  by   the  National  Director.      If 
interpreted   and   followed  as   we  expect    It   to   be,    a   high   level  of  output   can  be  expected 
without   undue   environmental   degradation. 

SUMMARY 

(1)   The   highest   possible    level  of   timber  production   should  be   the   goal 
consistent  with  applicable    laws    and  regulations.    (2)   Amenities   not   required  by   law 
should  be  carefully  blended  within   the   the    timberland  base    in  e  manner   thaC   does 
not   unduly  interfere  with  timber  production.      (3)    Budget   requirements  of   each  Alt- 
ernative must   be  known  before   a  decision  can  be  made.      (4)   All    incensive  managemenc 
practices  with  a   positive   B/C   should  be   Included  regardless  of  which  Alternative 
is  selected. 

CONCLUSION 

In  consideration  of   the   above   and   the    information  within   the  DEIS,    we  believe 
that   the  output    level  of   timber  can  be   higher  than   that   of   the  Proposed  Action. 
Without   the  benefit   of   computer   data  and   professional   assistance,   Alternative  2, 
combined  with  the   adjustments   required  by  the  new   criteria,    appears    to   be  our 
preference.      We   also  note   chat  Alt.    2   reaches   che   regulated   position   in   less   time 
and  that   the   period  where   some   50   year  old  stands  will   be   harvested   is    shorter 
by  one   decade. 

Finally,    we  commend  you  and  your   able  staff   for   a   job  well   done.     The   DEIS 
reflects   sincerity,    devotion   and   inventiveness.     We  know  that   you  will   take  our 
comments    In  the   constructive    light    that    is   intended. 


Respectfully  submitted 


Ray  E.   Doerner,   Exec.   Dir. 


Response  to  comments  in  Letter  69. 

69-1         Neither  the  district's  planning  criteria  (Appendix  C)  nor  the  O&C 
Forest  Resources  Policy  (Appendix  A)  suggest  that  choice  among 
alternatives  will  be  based  on  funding  requirements.  Common  issue  2 
projects  the  district's  timber  sale  offerings  if  funding  were 
insufficient  to  meet  the  district's  commitments  to  intensive 
management  in  Alternative  9,  the  Preferred  Alternative. 

69-2         Generally,   fertilizing  unthinned  stands  more  than  10  years  prior  to  a 
commercial    thinning  entry  or  final  harvest  does  not  yield  an  economic 
return.  Fertilization  plans  in  the  Preferred  Alternative  (Alt.  9) 
include  unthinned  stands  which  exhibit  spacing  characteristics  of 
thinned  stands. 

69-3         The  Preferred  Alternative  includes  special  visual  considerations  for 
BLM  recreation  areas  and  State  of  Oregon  designated  scenic  areas. 
Refer  to  DEIS,  Chapter  3,  page  82.  Also,  see  response  to  comments 
58-2  and  58-3. 


71 


133 


Western    Forest   Industries  Association 

1S0O      S      W.     TAYLOR      STREET      •      PORTLAND.     ORECON  97205 

TE  LEPHON  E 
SO  3  -  224- 5455 

August  18,  1982 


Mr.  James  E.  Hart,  District  Manager 
Roseburg  District  Office 
Bureau  of  Land  Management 
777  N.W.  Garden  Valley  Blvd. 
Roseburg,  Oregon  9 74 70 

Re:   Roseburg  Timber  Management  Draft  Environmental  Impact  Statement 

Dear  Mr.  Hart: 

Western  Forest  Industries  Association  (WFIA)  appreciates  the  oppor- 
tunity to  comment  on  the  Draft  Environmental  Impact  Statement  for  the 
Roseburg  District  Timber  Management  Plan  and  your  proposed  action.   Our 
Association  is  comprised  of  approximately  100  manufacturers  of  lumber 
and  plywood  with  mills  located  throughout  several  western  states.   These 
firms  are  primarily  small,  independently-owned  businesses  that  share  a 
mutual  dependence  on  timber  produced  on  public  forest  lands  for  a  source 
of  raw  material.   Several  of  our  members  are  major  purchasers  of  BLM 
timber  in  western  Oregon,  including  the  Roseburg  District.   Consequently, 
we  have  been  deeply  involved  in  reviewing  the  timber  management  proposals 
being  prepared  by  several  BLM  districts.   The  future  viability  of  our 
members,  and  the  stability  of  the  communities  that  are  dependent  on  their 
operations,  will  be  determined  by  the  long-term  productivity  of  public 
forest  lands. 

In  quite  simple  terms,  we  believe  the  future  availability  of  timber 
from  public  lands  will  be  determined  by  the  amount  of  commercial  forest 


71-1 


Mr.  James  E.  Hart 
August  18,  1982 
Page  Two 


land  preserved  for  timber  production  purposes.   Our  goal  in  participating 
in  your  planning  process  is  to  maintain  or  expand  the  intensive  timber 
production  base.   This  goal  is  shared  by  the  Oregon  State  Department  of 
Forestry  in  its  objectives  for  the  Forestry  Program  for  Oregon  and  by 
the  House  of  Representatives  of  the  Oregon  State  Legislature  (see  House 
Memorial  ffl,  enclosed).   Unfortunately,  all  of  the  BLM  proposals  made 
to  date  are  inconsistent  with  this  goal.   Your  proposal  is  no  exception. 
While  timber  production  will  increase  by  48  million  board  feet  per  year 
under  your  proposed  action,  the  increase  in  yield  will  occur  on  nearly 
44,000  fewer  acres.   In  order  to  implement  the  alternative,  significant 
increases  in  intensive  forest  management  investments  will  be  required. 
As  an  Association  of  forest  industry  concerns,  WFIA  applauds  your  leader- 
ship in  promoting  the  latest  scientific  advancements  in  forestry.   How- 
ever, we  do  not  support,  and  in  fact  oppose,  the  use  of  intensive  manage- 
ment investments  as  a  vehicle  to  trade  away  productive  forest  land  for 
unsubstantiated  non-timber  uses.   Paramount  among  our  many  concerns  is 
the  outlook  for  revenue  to  finance  the  intensive  management  program  you 
have  proposed.   Your  cash  flow  scenario  assumes  future  stumpage  prices 
in  excess  of  $300/MBF  and  that  timber  currently  under  contract  will  be 
harvested.   In  light  of  the  less  than  certain  future  for  funding  intensive 
management,  it  would  seem  prudent  to  analyze  some  alternative  means  of 
achieving  the  same  timber  production  objectives  suggested  in  the  proposed 
action.   We  believe  the  most  viable  option  is  to  increase  the  amount  of 
land  allocated  to  intensive  timber  production.   Such  an  alternative  would 
most  likely  result  in  a  more  cost  efficient  method  of  achieving  your  tim- 
ber harvest  goal.   The  major  deficiencies  of  the  Draft  Environmental 
Impact  Statement  that  lead  us  to  this  conclusion  are: 

1.   No  analysis  of  the  opportunity  costs  of  re- 
moving productive  forest  land  from  the  in- 
tensive timber  production  base. 


Mr.  James  E.  Hart 
August  18,  1982 
Page  Three 


Mr.  James  E.  Hart 
August  18,  1982 
Page  Four 


71-2 


71-3 


2.  Faulty  analysis  of  expected  revenues. 

3.  Inadequate  cost  data  for  implementing  each  of 
the  alternatives. 

4.  Erroneous  cost  efficiency  analysis. 
Each  of  these  concerns  will  be  addressed  individually. 
OPPORTUNITY  COSTS 

The  proposed  action  includes  several  classifications  of  lands  placed 
in  the  Constrained  Timber  Production  Base.   Habitat  for  spotted  owls, 
old  growth  blocks  of  various  sizes,  osprey  and  heron  habitat,  riparian 
zones  and  visual  management  areas  totaling  52,047  acres  will  be  placed 
in  the  constrained  base  and  managed  under  area  control.   It  is  imperative 
that  the  opportunity  foregone  in  terms  of  timber  production,  income  to 
the  Federal  Treasury  and  the  counties,  and  the  benefits  to  dependent 
communities  be  assessed  for  each  of  these  resource  allocations.   The 
tradeoffs  involved  in  removing  productive  land  for  each  of  these  non- 
timber  uses  can  be  best  assessed  by  disclosing  the  opportunities  fore- 
gone in  this  manner.   The  public  will  be  in  a  better  position  to  under- 
stand the  relative  costs  and  benefits  of  these  resource  allocations. 
REVENUES 

Table  B-2  on  page  116  of  the  Draft  EIS  displays  an  erroneous  repre- 
sentation of  expected  revenues.   For  example,  revenues  expected  in  1984 
are  calculated  by  multiplying  the  price  of  stumpage  ($302/MBF)  by  the 
proposed  action  harvest  level  of  249  million  board  feet.   There  are  two 
major  flaws  in  this  prediction.   First,  timber  sales  harvested  in  1984 
will  be  those  sold  in  1981  and  have  very  different  stumpage  values  than 
those  displayed  in  Table  B-2.   Second,  the  volume  harvested  in  1984  will 


71-3 


71-4 


71-5 


more  nearly  reflect  the  sale  program  in  effect  in  1981,  i.e.  201  million 
board  feet.   Likewise,  volume  harvested  in  1985  will  be  from  sales  sold 
in  1982,  etc.   Therefore,  the  expected  revenues  displayed  in  Table  B-2 
are  overstated  for  1984,  1985  and  1986.   Furthermore,  the  stumpage  rates 
forecasted  for  the  planning  period  may  well  be  optimistic.   Some  documenta- 
tion should  be  provided  in  the  EIS. 

COST  DATA  BY  ALTERNATIVE 

In  order  to  perform  an  acceptable  economic  analysis  of  each  alterna- 
tive, the  cost  of  implementing  each  alternative  is  necessary.   Table  B-l 
displays  the  forest  management  costs  for  the  proposed  action  but  does  not 
include  total  costs  or  itemized  district  and  State  overhead  costs.   These 
cost  figures  should  be  displayed  for  each  alternative,  along  with  expected 
revenues  for  each  alternative,  and  discounted  back  to  present  net  value. 
Data  displayed  in  this  manner  will  facilitate  a  more  accurate  assessment 
of  the  relative  efficiency  of  each  alternative. 

SOIL  EXPECTATION  VALUES 

Your  use  of  soil  expectation  values  in  assessing  the  economic  effi- 
ciency of  management  regimes  is  extremely  misleading.   Bare  land  economics 
may  be  useful  in  determining  the  relative  efficiency  of  alternatives,  but 
the  negative  values  displayed  in  Tables  B-3  through  B-4  imply  that  the 

I  management  practices  are  not  cost  effective.   Why  you  chose  this  method 
of  analyzing  management  opportunities  is  not  clear.   The  fact  is,  the 
Roseburg  District  has  a  large  volume  of  standing  inventory  that  is  ex- 
tremely valuable.   We  believe  it  is  inappropriate  to  ignore  this  value  in 
calculating  the  costs  of  producing  the  next  rotation.   Specifically,  re- 
forestation costs  should  be  viewed  as  a  cost  against  harvesting  the  exist- 
ing stand,  not  in  establishing  a  future  stand.   Existing  laws  and  regula- 
tions require  that  reforestation  be  assured  prior  to  making  a  decision 


134 


Mr.  Jan 

August  18,  1982 

Page  E i 


Mr.  James  B.  Mi r t 
August  18,  1982 
Page  Six 


to  h.ir  to  charge  reforestation 
and  associated  costs  again            Lng  stand  rather  than  the  future 
stand.   The  existing  stand  could  not  be  cut  without  a  commitment  to  ro- 
tation.  An  analysis  of  the  man ...  >  !  izlng  this  more 
traditional  approach  will  i           more  accurate  assessment 

The  Final  Environmental  Impact  Statement  should  include  Information 
to  satisfy  the  shortcomings  described  above.   We  believe  the  additional 
analysis  will  demonstrate  that  the  proposed  action  is  a  very  risky  alter- 
native relative  to  funding,  will  result  in  tremendous  opportunity  costs 
in  terms  of  intensive  timber  base  reductions,  and  may  we]  cost 

efficient  than  some  alternative  land  base/Intensive  management  mix. 

RECOMMENDATIONS 

We  ask  that  an  alternative  with  a  land  use  allocation  similar  to 
Alternative  #2  be  given  consideration  as  the  proposed  action.   Such  an 
alternative  would  strike  a  compromise  between  current  land  uses  and  those 
suggested  in  the  current  proposed  action.   Of  greatest  significance,  an 
intensive  timber  production  base  of  approximately  300,000  acres  would  not 
be  as  sensitive  to  budget  short-falls  as  the  current  proposal.   In  case 
of  funding  shortages,  subsequent  reductions  in  timber  harvest  would  not 

My  as  significant.   In  addition,  the  benefit/cost  relationship 
would  be  more  favorable  since  it  would  require  a  smaller  investment  in 
intensive  management  to  yield  the  same,  if  not  higher,  harvest  level. 

Our  recommended  alternative  would  also  be  consistent  with  the 
Director's  July  15,  1982,  Criteria  for  Application  of  0  &  C  Forest  Policy. 
The  current  proposed  action  is  not.   Specifically,  compliance  with 
Criteria  "5  would  be  better  accommodated  by  Alternative  #2  in  regard  to 


the  allocation  of  commercial  foi 

native  would  also  maintain  future  options  for  preserving  old  growth  tim- 
ber stands.  At  the  end  of  the  planning  period,  over  70,000  acre*  of  old 
growth  timber  would  remain  on  the  district 

acres  of  old  growth  would  remain;  more  than  enough  to  sustain  a 
population  of  spotted  owls. 

When  all  the  major  criteria  arc  considered;  I  ncy  of  local 

communities  on  the  timber  resource,  the  goals  of  I  ,  irtment  of 

Forestry,  House  Memorial  #1,  the  Director's  Criteria  for  Application  of 
0  &  C  Forest  Policy,  the  tremendous  cost  of  the  proposed  action,  the  un- 
certain outlook  for  funding  intensive  management  practices,  the  cost/ 
benefit  relationship  of  the  proposed  program,  and  the  over  abundance  of 
old  growth  timber,  Alternative  02  Is  the  most  prudent  and  logical  choice 
for  final  adoption. 

Very  truly  yours, 

WESTERN   FOREST   INDUSTRIES  ASSOCIATION 


,  1H 


Mr.    William  Leavell 
Mr.    Robert   Burford 


Jj£(  Gelslnger  /J 


ORECONLECISI  VTIV 


House  Memorial  1 


c  ichucm  ol  Represents 


The  following  lurtunury  is  ™.i  pn  . 

!■■,  ti,,-  I  egislative  Assembly,     li 
ininduont. 

Urges  I  niled  Slates  Bureau 


and   Ho 


I..  ihu   Honorable 

assembled 

Wc,    youi    memorialists,    tra    House   ol    Represents 
assembled    most  respectful!)  request  il 
Management  kind  use  planning  in  Oregon  and  specifically 

Whin-. in  umber  management  proposal 
preparation  in  all  Bureau  of  Land  Managcm 


Hoi  si    Ml. MORI  VI    i 
f  Representatives  i>(   ihe   United  State*  of    America, 


..l    the   State  of  Oregon,  in  legislative  session 
,  to  intervene  in  the  Bureau  of  Land 
in  <  'oos  B.iv  district  because 
being  developed  in  the  Coos  B.iy  district  and  in  plans  under 
districts  in  western  Oregon;  and 
Whereas  the  limbei  manag.  n  !  '  -,nd  Management's  Coos  Bay  d.smci 

k  vul  bj  Id  million  board  feci,  eliminate  over  -00  jobs  in  the 
local  area  and  reduce  count)  limbei  revenues  by  2  t  million  dollars;  and 

Whereas  the  pni  ihe  prop«>sed  reduc 

reduce  the  intensive  umber  production  base  b] 


i>  I  he  Bureau  of  Land  Management's  decision  to 
HI  acres  lor  the  exclusive  benefit  of  wildlife  and 


■.iheiK 


and 


-natives  have  been  developed  < 

icd  yield  ■ • 


ol  Land  Managcmenl  thai  would  allow  , 

v  jobs  in  one  of  the  most  depressed  areas 


Whereas  the  revesting  Act  of  Or.  Bay  Wagon  Road  Grant  l^nds  (43 

:  •  lal  that  governs  management  ol  mosi  Burv; md  Managcmenl  lands  in  western  Oregon  specifics 

I      "n,K  ««M»reo( 

dependent  communities,  .md 

Whereas  the  Oregon  economy  is  dependent  or,    I  sting  and  processing  of  renewable  timber 

anil 

Whereas  other  Bureau  of  Land  Management  districts  in  western  Oregon  are  following  the  precedent  set  by 
[he  t  oos  Bay  district  by  proposing  reductions  in  the  Immci  production  land  base  for  nontimber  uses  al  the 
expense  of  limber  supply,  employment  ai  m  of  dependent  communities;  now.  therefore. 

Ik  ll  Resolved  b)  the  Housf  uf  Reprwrnlutnes  ol  the  Stall  »l  i  irego" 


(1)  Wc  urge  the  Congress  of  Hi    United  States  to  reqi 
priority  to  the  following  goals  in   i.  a  king  final  decisions 

Kcemphawc  the  importance  of  ^immunity  stabilily. 
individual   planning  districts,  and    make  certain  evt 


1  iii. i  Hie  Bureau  <•(  LmJ  Managcmenl  give  highesl 

lht  i  ik»  He  district  and  olher  western  districts 

oil  and  'a*  base  within  Oregon  and  its 

y    possible   effori    is   made   lo  preserve   the   intensive 


land  Kisc  lor  umber  production  purposes 

lonal  shall  be  transmitted  to  each  mcmhci  "i  the  Oregon  Congressional  Delegation 
to  e.iJi  ol  Hs  Oregon  district  offices  for  inclusion  ii 


manage 

(2)  A  copy  of  this 
lo  (he  Director  of  the  Bureau  of  1  .md  Management 
the  hearings  on  each  district  land  use  plan 


ft; 
ft 


74 


Response  to  comments  in  Letter  71. 


71-1         See  response  to  common  issue  2. 


71-2         See  response  to  common  issue  4. 


United  States  Department  of  the  Interior 

MSII  AND  WII  IH  1H  SERVIC'l 

Portland  I 
Reference:  ES  V/l   N. 

Portland, 


135 


71-3         See  response  to  comment  68-20. 


71-4         Table  B-l   in  the  FEIS  includes  cost  data  for  Alternatives  4  and  9. 
Also,   see  response  to  comment  68-21. 


71-5         See  response  to  comment  68-19. 


74-1| 


74-2 


74-3 


To:     Roseburg  District  Manager,  Bureau  of  Land  Management 
Roseburg,  Oregon 

From;    Field  Supervisor,  Oivision  of 
Portland,  Oregon 

Subject:  Review  of  the  Roseburg  Timber  Management  Graft  Enviroi 
Statement,  Douglas  County,  On 

We  have  reviewed  the  subject  draft  environmental  statement  on  I 
Timber  Management  proposal  and  provide  the  following  comments: 

General  Comments 

Based  on  the  information  submitted,  the  proposed  management  plan  could  \\^h 

a  significant  adverse  impact  on  area  fish  and  wildlife  resource',. 

document  does  not  discuss  impacts  associated  with  the  preferred  alten 

in  conjunction  with  anadromous  and  resident  fish.   In  addition, 

concerning  the  displacement  of  wildlife  through  habitat  reduc'  i 

more  detailed  in  the  final  document.  It  is  also  unclear  whether  wetland 

areas  within  the  management  unit  will  be  affected. 

It  is  our  belief  that  proper  guidelines  and  selected  mitigative  me  a-  i 
should  be  coordinated  with  any  comprehensive  plan  that  you  subsequently 
adopt.  The  final  document  should  also  consider  all  practicable  means  and 
measures  that  could  best  satisfy  identified  needs  while  at  the  same  t 
protecting,  preserving,  and  enhancing  the  quality  of  the  environment, 
restoring  environmental  quality  previously  lost,  and  minimizing  and 
mitigating  unavoidable  adverse  effects.  We  dre   especially  concerned  about 
maintaining  a  reasonable  riparian  buffer  strip  in  association  with  each 
stream  corridor.  Also,  bank  protection  is  important  in  helping  to  reduce 
potential  sedimentation  and  temperature  increases. 

Specific  Comments: 

page  5,  para  2.  There  is  no  discussion  concerning  the  adverse  impacts  the 
proposed  management  would  have  on  the  fish  population  in  the  area. 
Additional  data  should  be  provided  in  the  final  statement. 


I  page  24-25,  table  1-5.  The  "summary  of  impacts"  table  does  not  reflect  any 
impacts  on  fish  or  their  associated  habitat.  This  catagory  should  be 
included. 

-i  page  45,  para  2.  There  is  no  indication  what  portion  of  the  existing 
74"4l  riparian  habitat  will  be  altered.  This  should  be  addressed  in  the  final 
document. 

ipage  66,  para  4.  Discussion  of  Impacts  on  riparian  habitats  and  streams  by 
erosion,  landslides,  nutrient  depletion  and  road  construction  should  be 
expanded  and  presented  in  more  detail  in  the  final  document.  Mitigative 
_-  £tl  measures  should  be  implemented  to  prevent  any  long  term  adverse 
7*r'"v|  environmental  impacts. 

page  77,  para  6   A  number  of  factors  which  can  adversely  affect  fish  are 
presented,  however,  the  amount  of  impact  the  various  alternatives  would 
have  has  not  been  discussed. 

pages  77-78.  The  harvesting  of  timber  does  have  an  adverse  impact  on  fish 
habitat  by  removing  the  riparian  zone,  changing  water  yields  and  increasing 
the  sedimentation.  Therefore,  these  areas  should  be  quantified  as  much  as 
possible  and  included  in  the  final  document. 

We  appreciate  having  had  the  opportunity  to  review  this  draft.  Please  feel 
free  to  contact  us  if  you  have  any  questions  concerning  our  comments. 
We  would  also  appreciate  receiving  a  copy  of  the  final  statement  when  it 
becomes  avai lable. 


74-7 


I^J^dJ^^r^ 


Russel 1   D.   Peterson 


Response  to  comments  in  Letter  74. 

74-1         Wetland  areas  are  included  as  riparian  habitats  and  thus  would  be 
affected  by  each  alternative  as  described   in  the  DEIS-  Chapter  3, 
Impacts  on  Animals,   page  75.   It  should  be  noted  that  the  percent  of 
riparian  habitat  associated  with  wetlands   is  quite  small   on  BLM  lands 
within  the  EIS  area. 

74-2         See  response  to  comment  5-3. 

74-3         Impacts  are  described   in  Chapter  3  of  the  EIS.   Because  the   ai 
in  Chapter  3  concluded  the  impacts  on  fish  populations  would 
significant,   those  impacts  are  not  listed   in  the  summar 
Chapter  1. 

74-4         Refer  to  EIS  Chapter  3,  Vegetation  Section  and  Appendix  Cf  Table  C-4, 
for  discussion  on  the   impacts  to  riparian  areas  from  each 
alternative. 


74-5         See  response  to  comments  5-3  and  74-4-    as  indicated  on  page  26  of  the 
DEIS,   additional   environmental   assessment  of  timber  sales  will 
address  riparian  habitat,  erosion,  landslides  and  road  construction. 

74-6         See  response  to  comment  5-3. 


74-7         See  response  to  comment  74-3. 


78 


136 


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137 


Response  to  comments  in  Letter  78. 


78-4 


*#-&£  £>.    t^^rU-LO^ 


78-1         See  response  to  comment  12-1. 

78-2        Table  B-2  has  been  revised  to  increase  the  number  of  baselines  for 
forecasting  revenue. 

78-3         See  response  to  common  issue  5 . 

78-4         The  existence  of  "surplus  inventory"   is  closely  linked  to  both  actual 
and  potential  harvest,  as  described   in  the  DEIS,  Appendix  C,  page 
127.  The  lack  of  surplus  inventory  for  the  Roseburg  District  is 
partly  due  to  the  high  level  of  intensive  management  practices 
scheduled. 


80 


"Monte     Montgome 
President 


Auqust  20,  1982 


James  E.  Hart 

District  Manager 

BLM  Roseburg  District  Office 

777  NW  Garden  Valley  Blvd. 

Roseburg,  Or   97470 

Dear  Mr.  Hart: 

Associated  Oregon  Loggers  (AOL)  is  submitting  the  attached  analy- 
sis of  the  Roseburg  District  draft  environmental  impact  statement 
(DEIS) ,  in  response  to  your  request  for  comments .   We  enthusiast i- 
cally  support  the  District's  obvious  commitment  to  increase 
timber  supply,  jobs  and  county  revenues.   AOL  has  maintained  its 
commitment  to  long  range  forest  planning,  despite  the  current 
economic  crisis,  and  we  applaud  the  District' s  efforts  to  plan 
for  a  future  where  once  again  there  is  a  healthy  demand  for 
Oregon's  forest  products. 

Since  the  State  Director  has  advised  the  Roseburg  District  that 
the  proposed  action  must  be  amended  to  conform  with  new  policy 
d irect ion,  AOL  will  withhold  its  final  support  of  an  alternative 
until  we  have  the  oppor tuni ty  to  review  the  new  proposed  action. 
We  do  believe,  however,  that  Alternative  2  provides  a  good  foun- 
dation for  the  new  proposed  action . 


As  was  suggested  by  Bob  Alver 
comments  in  the  attached  anal 
DEIS  to  meet  laws  and  regulat 
does  not  comply  with  several 
tions  (Subpart  1601) ,  related 
State  goals,  wildlife  habitat 
implementation.  AOL  also  bel 
not  comply  with  the  0  &  C  Act 
dations  for  improving  the  DEI 
impact  statement  (FEIS)  into 
tions. 


ts,  your  planning  coordinator ,  our 
ysis  focus  on  the  adequacy  of  the 
ions.   AOL  believes  that  the  DEIS 
sections  of  the  BLM  planning  regula- 
to  process  papers,  consistency  with 
,  economic  and  budget  analysis,  plan 
ieves  that  the  proposed  action  does 

AOL  makes  a  number  of  recommen- 
S  to  brinq  the  final  environmental 
compliance  with  laws  and  regula- 


We  look  forward  to  continued  involvement  in  your  planning 
process. 


Sue 
Pores 


Executive  Committee 

Dan  Pugate 

Bob  Birkenfeld 

F.  F.  (Monte)  Montgomery 

Bob    Lindsay  AFF|RMAT|V£  ACT|0N  _   EQUAL  OPPORTUNITY  EMPLOYER 


ASSOCIATED    OREGON    LOGGERS    ANALYSIS 

OF    THE    BLM    ROSEBURG    DISTRICT 

DRAFT    ENVIRONMENTAL 

IMPACT    STATEMENT     (DEIS) 


The  discussion  below  addresses  six  areas  of  the  DEIS,  which  AOL 
believes  are  inadequate  to  meet  BLM  laws  and  planning  regula- 
tions. 


0  &  C  ACT 

The  Solic 
concluded 
dominant 
states  th 
can  best 
In  the  ca 
will  occu 
has  analy 
each  Act 
signif ica 


itor  General's  opinion,  dated 

that  the  O  6  C  Act  mandates 
use  on  BLM  managed  O  &  C  land 
at  "the  Bureau  must  see  how  w 
be  achieved  on  land  not  avail 
se  of  those  areas  of  land  whe 
r,  the  Bureau  may  choose  one 
zed  its  choice  in  the  context 
and  is  satisfied  that  the  par 
ntly  encroached  upon  the  over 


September  8,  1981, 
forest  production  as  the 
s.   The  opinion  further 

ldlife  protection  goals 
able  for  timber  production. 
re  direct  conflict  in  use 
over  the  other  provided  it 

of  the  principle  goals  of 
ticular  choice  has  not 
all  effect  of  these  goals." 


This  direction  from  the  Solicitor  General  implies  that  the  BLM 
must  prepare  a  well  documented  analysis  or  process  paper  which: 

1.  Assesses  the  location,  quality  and  quantity 
of  wildlife  habitat; 

2.  Defines  adequate  protection  for  wildlife  habitat; 

3.  Distinquishes  between  0  &  C  lands,  and  public 
domain  lands; 

4.  Locates  wildlife  habitats,  for  each  alternative, 

on  0  &  C  lands  not  available  for  timber  production; 
and, 

5.  Documents  the  economic  and  social  consequences  of 
allocating  O  s  C  lands  to  wildlife  habitat,  if  this 
allocation  is  necessary. 

Although,  this  opinion  has  been  in  circulation  for  over  a  year 
now,  and  the  Roseburg  District  states  that  they  did  an  analysis 
of  how  to  meet  wildlife  habitat  concerns  on  non-productive  0  &  C 
lands,  there  is  non  process  paper  documenting  compliance  with  the 
0  &  C  Act  as  Solicitor's  opinion.   Section  1601.7-1,  of  the  BLM 
planning  regulations,  states  that: 


138 


10-1 


"Records  pertaininq  to  the  analysis  and 
conclusions  reached  by  the  Ditrict  Manager 
and  staff  throuqhout  the  planning  and 
environmental  analysis  process  shall  be  maintained. 
...Such  records  shall  be  kept  filed  together 
and  shall  be  available  on  request  for  public 
review. " 

*A0L  recommends  that  a  proposed  action  be  developed,  which 
complies  with  the  0  &  C  Act  and  Solicitor's  opinion. 

*A0L  recommends  that  the  final  environmental  impact  statement 
(FEIS)  include  a  process  paper  which  documents  the  allocation  of 
0  6  C  lands  to  timber  production  and  wildlife  habitat.   This 
information  is  of  critical  public  concern,  especially  with  the 
new  Washington  and  State  office  direction  on  this  issue. 


FORESTRY  PROGRAM  FOR  OREGON 


ntenance  of  the  commercial  forest  land 
e  level,  is  of  great  concern  to  AOL.   We 
all  alternaties,  except  #1  and  #5,  are 
of  Forestry  objective  regarding  main- 
Section  1601.4  (c)  (1),  of  the  BLM 
ates  that  resource  management  plans  will 
sible  with  existing  officially  adopted 
lated  policies,  plans  or  programs 

The  proposed  action  reduces  the  land 
1.6%).   AOL  believes  that  the  BLM  has  not 
tion  to  comply  with  Section  1601.4  (c) 


As  we  discuss  below,  mai 
(CFL)  base  at  a  resonabl 
noted  in  Table  1-7  that 
inconsistent  with  Board 
tenance  of  the  CFL  base 
planning  regulations,  st 
be  "as  consistent  as  pos 
and  approved  resource  re 
of... state  agencies 
base  by  43,779  acres  (-1 
designed  the  proposed  ac 
{1)  as  required. 

*AOL  recommends  that  the  FEIS  reconsider  the  size  of  the  commer- 
cial forest  base  in  each  of  its  alternatives.   The  planning 
regulations,  we  believe,  call  for  at  least  minimal  consistency 
with  the  state's  land  base  objective.   The  BLM  must  increase  the 
size  of  the  proposed  actions  commercial  forest  land  base  in  order 
to  comply  with  1601.4  (c)  (1). 

WILDLIFE  HABITAT 

Over  52,000  acres  of  the  Roseburg  District  have  been  allocated  to 
wildlife  habitat  or  visual  management  areas.   At  the  end  of  the 
10th  decade  of  the  projection,  18  owls  are  expected  using  the  300 
acre  management  assumption,  while  no  owls  are  expected  using  the 
1,000  acre  assumption.   Futhermore,  it  is  projected  that  a 
"medium"  amount  of  degradation  of  scenic  quality,  will  occur. 


Section  1601.5-4  (a)  (9)  of  the  BLM  planning  regulations,  which 
describes  the  analysis  of  the  management  situation  process,  states 
that: 

"The  District  manager  shall  analyze  the  management 
situation  to  determine  the  capability  of  the  public 
land  resources  to  respond  to:   Needs,  concerns  and 
opportunities  identified  through  public 
partlciation. . . " 

This  section  further  states  that  critical  threshold  levels  should 
be  considered  during  the  formulation  of  plan  alternate 

*AOL  recommends  that  in  order  to  fully  comply  with  these  regula- 
tions, the  BLM  should  conduct  a  trade-off  analysis  of  the  55,047 
QQ.2  constrained  acres  to  document  the  effects  (in  terms  of  allowable 
harvest  and  budget  requirements)  of  incrementally  adding  these 
acres  back  into  the  intensive  timber  management  base.   The  BLM 

I  should  further  provide  a  listing  of  spotted  owl  pairs  by  decade 
for  ech  alternative.   This  should  include  the  amount  of  habitats 
under  both  the  300  acre  and  1,000  acre  assumption. 

ECONOMIC  AND  BUDGET  ANALYSIS 

The  BLM  conducted  several  economic  and  budget  analyses,  on  the 
proposed  action  for  the  Roseburg  District,  as  requested  by  the  public. 

Section  1601.5-2  (a),  of  the  BLM  planning  regulations,  defines 
the  purpose  and  use  of  planning  criteria. 

"Planning  criteria  shall  be  used  to  evaluate 
alternatives  and  to  select  one  alternative  to 
serve  as  the  proposed  resource  management  plan." 

One  of  the  criteria  developed  for  the  Roseburg  District  states 
that: 

"Each  alternative  was  evaluated  according  to  the 
degree  to  which  it  would. . .provide  for  a  high  level 
of  contribution  to  local  public  revenues  from 
resources  and  activities  available  on  public  lands." 

Since  economic  and  budgetary  analysis  where  conducted,  only  on 

the  proposed  action  and  Alternative  3  it  is  difficult  to 

understand  how  the  BLM  used  the  above  criterion  to  select  the 
proposed  action. 

-3- 


J04 


*A0L  recommends  that  an  economic  and  budget  analysis  be  conducted 
foe  each  alternative.   Only  in  this  way  can  the  "revenue"  cri- 
teria be  properly  used  to  select  the  proposed  action,  which  will 
not  only  provide  a  high  level  of  contribution  to  local  and  public 
revenues,  but  will  also  have  a  budget  that  is  fundable. 

PLAN  IMPLEMENTATION 

The  proposed  action  reduces  the  commercial  forest  land  base  by 
43,779  acres  (-11.6%)  and  increases  the  constrained  land  base  by 
38,161  acres  (+73.3%).   Precommercial  thinning  acres  are 
increased  28,429  acres  (+230%),  fertilization  is  increased  56,02^ 
acres  (+100%),  site  preparation  is  increased  23,723  acres 
(+30%),  and  planting  is  increased  is, 795  acres  (+30%).   Finally, 
the  required  budget  for  the  forest  management  and  development 
would  increase  from  50.7  to  83.8  million  (Table  B-7)  dollars  in 
decade  1,  a  65%  increase. 

From  these  figures,  it  is  apparent  that  the  District  has  huilt  a 
very  costly  proposed  action  in  order  to  accomodate  multiple  uses 
of  the  forest  resource.   In  order  to  increase  the  allowable  cut 
level,  on  a  reduced  land  base,  a  costly  array  of  intensive  manage- 
ment practices  has  been  proposed  by  the  BLM.   Since  the  BLM  now 
obtains  its  funding  for  forest  management  by  congressional 
appropriation,  the  huge  budget  requirement  of  the  proposed  action 
(a  65%  increase  from  the  present  budget)  may  not  be  able  to  be 
completely  funded. 

If  the  Roseburg  District  does  not  receive  full  funding  for  the 
proposed  action,  then  the  level  of  intensive  management  scheduled 
cannot  be  achieved  and  the  annual  allowable  harvest  level  must 
be  reduced.   Certainly  the  most  cost  effective  way  to  raise  har- 
vest levels  it  to  maintain  the  number  of  commercial  forest  land 
acres  allocated  to  intensive  management.   Smaller  quantities  of 
costly  intensive  management  practices  could  be  utilized  on  a 
larger  land  base  to  reach  the  same  allowable  cut  level. 

*AOL  supports  the  choice  of  implementable  plans  and  the  main- 
tenance of  the  commercial  forest  land  base  at  a  reasonable  level. 
The  proposed  action  is  not  acceptable  because  of  its  reduced  land 
base  and  high  budget  requirements,  which  hinder  its  ability  to  be 
implemented.   Development  and  approval  of  unimplementable  plans 
certainly  violates  Section  1601.0-2,  of  the  BLM  planning  regula- 
tions, which  states  that  the  objective,  of  Subpart  1601,  is  to 
"improve  resource  management  decisions  on  public  lands..." 

-4- 


Response  to  comments  in  Letter  80. 

80-1         BLM  planning   regulations  became  effective  September  6,  1979.  The 

December  3,   1979  Federal  Register  included  a  display  of  BLM  planning 
efforts  underway  on  that  date.  Roseburg  District  was  shown  as  a 
Category  C,  district-wide  Management  Framework  Plan  revision  to  which 
the  new  regulations  were  only  partially  applicable.  Although 
regulation  1601.7-1  is  applicable  to  the  Management  Framework  Plan, 
through  the  development  of  a  preferred  alternative,    it  does  not   apply 
to  the  Timber  Management  EIS. 

The  preferred  alternative  and  other  alternatives  considered  have  been 
presented  in  a  summary  brochure  prepared  in  September  1981,  which 
indicates  land  use  allocations  applicable  to  EIS  Alternatives  1,  4,  6 
and  8.  Refer  to  DEIS,  Appendix  C,  Tables  C-2,  C-3,  and  C-4  for 
allocations  by  alternative.  Analysis  in  the  FEIS  includes  Alternative 
9,  which  is  based  on  the  new  C*C  Forest  Resources  Policy  (Appendix 
A). 

80-2         See  response  to  common  issue  4. 

80-3         The  entire  43  CFR  1601.5-4  regulation  section  is  not  required  for  any 
transition  period  Management  Framework  Plan.  Also,  see  response  to 
comment  11-8. 

80-4         See  response  to  comments  68-19,  68-21  and  69-1. 


83 


139 


nORTH  WEST  TimBER  RSSOCMTIOII 


13S6  OAK  STREET 
TELEPHONE   15031 


PO  BOX  5554 
6869603 


EUGENE  OREGON  9)405 


August  20,  1982 


Mr.  James  Hart 

District  Manager 

Bureau  of  Land  Management 

777  NW  Garden  Valley  Blvd. 

Roseburg,  OR  97470 

Oear  Mr.  Hart: 

On  behalf  of  North  West  Timber  Association  I  am  pleased  to  comment  on  the  Draft 
EIS  for  the  District's  new  Timber  Management  Plan.  Our  Association  consists  of 
small  independently  owned  lumber  and  plywood  manufacturers  in  western  Oregon 
and  southwestern  Washington,  including  several  firms  which  purchase  timber 
directly  from  the  Roseburg  District.  Our  members  are  almost  exclusively 
dependent  on  federal  land  for  their  timber  supply  thus  making  the  decision  for 
the  Roseburg  District  critical  to  the  survival  of  the  firms  and  the  economic 
stability  of  the  communities  in  which  we  operate. 

We  have  been  deeply  involved  in  the  planning  activities  of  all  the  western 
Oregon  districts  and  are  pleased  that  the  content  of  your  EIS  has  recognized 
many  of  the  problems  that  appeared  in  earlier  efforts.  Bureau  of  Land  Manage- 
ment planning  is  a  complex  and  difficult  task.   In  all  fairness,  we  compliment 
you,  as  well  as  the  District  and  State  staffs,  on  the  open  and  professional 
manner  in  which  you  have  conducted  the  planning  effort  and  attempted  to  accom- 
modate the  many  publics  interested  in  your  planning. 

At  the  outset  we  believe  it  is  essential  that  the  time  frame  of  the  planning 
decision  and  its  relationship  to  current  economic  conditions  be  put  in  perspective. 
The  new  plan  will  be  long  term  in  that  it  considers  effects  of  continuing  the 
plan  for  many  decades.  However,  in  reality,  it  is  relatively  short  term  in  that 
it  will  have  an  operational  life  of  approximately  one  decade  after  which  adjust- 
ments will  be  made  in  a  new  plan  to  reflect  changing  information  and  conditions. 
We  are  currently  in  the  worst  economic  recession  the  local  industry  has  ever 
seen  and  most- -if  not  al l--operations  in  the  county  are  struggling  with  the  very 
basis  of  survival.  Clearly  this  has  temporarily  affected  the  demand  and  value 
of  stumpage  and  it  may  be  several  years  before  conditions  return  to  "normal". 
We  as  an  Industry  are  optimistic,  however,  that  a  turn  around  will  occur  and 
that  timber  supply  will  return  as  the  major  controlling  factor  in  the  health 
of  our  Industry  and  local  economy.  When  this  will  occur  cannot  be  predicted, 
but  when  the  new  plan  is  implemented  in  1984  we  should  be  on  our  way. 


Mr.  James  Hart 


83-1 


August  20,  1932 


The  remainder  of  our  comments  will  fall  into  three  general  categories:  I)  The 
Planning  Process;  II)  Adequacy  of  the  EIS;  and  III)  Identification  of  a 
Proposed  Action. 

I)  THE  PLANNING  PROCESS 

Since  the  outset  of  the  planning  process  a  concern  has  existed  over  the  fact 
that  the  BLM's  procedures  did  not  provide  for  a  change  in  the  "Proposed  Action" 
(PA)  between  the  Draft  and  Final  EIS.  This  seems  to  have  changed  in  recent 
months  since  the  Salem  District  indicated  they  would  consider  changing  the  PA 
between  the  Draft  and  Final  EIS.  Furthermore,  the  July  15,  1982,  Criteria  for 
Application  of  0  8  C  Forest  Policy  from  Director  Bob  Burford  directs  that  the 
new  criteria  be  utilized  in  the  Roseburg  EIS  process. 

It  is  clear,  from  discussions  with  the  District  staff,  that  how  this  will  be 
implemented  is  still  a  matter  of  debate  to  be  addressed  in  analysis  of  input 
to  the  draft.  One  of  the  purposes  of  an  EIS  and  its  public  review  is  to  focus 
on  a  proper  decision.  Changes  from  the  current  PA  in  the  final  decision  will 
be  necessitated  by  the  Director's  criteria.  Therefore,  it  seems  only  logical 
that  the  process  be  facilitated  by  a  change  in  the  alternative  identified  as 
the  PA  in  the  Final  EIS.  This  will  not,  however,  require  that  the  PA  in  the 
Final  EIS  be  the  implemented  decision  since  the  draft  decision  process  remains 
intact. 

Contrary  to  State  memorandum  OR-82-601 ,  it  is  our  suggestion  that  the  planning 
team  attempt  to  identify,  from  the  existing  alternatives,  the  one  which  best 
meets  the  directive  on  0  &  C  criteria,  other  laws  and  decision  criteria  and 
identify  it  as  the  PA  in  the  Final  EIS.  Each  alternative  should  then  be 
analyzed  as  to  how  well  it  conforms.  The  EIS  will  then  point  out  changes  that 
may  be  needed  in  the  remaining  step  of  identifying  the  final  decision.  There 
is  no  reason  that  this  cannot  be  most  efficiently  accomplished  with  a  short 
form  Final  EIS. 

II)  ADEQUACY  OF  THE  EIS 

One  of  the  main  purposes  of  public  review  of  a  Draft  EIS  is  to  identify  areas 
where  the  statement  may  be  inadequate.  We  feel  that  additional  analysis  is 
needed  in  a  number  of  areas. 

A)  LAND  BASE  TRADE  OFFS.  The  reduced  timber  production  from  the  constrained 
timber  production  base  represents  some  opportunity  cost  in  terms  of  timber 
production  foregone.  While  a  comparison  between  alternatives  shows  the  over-all 
effect  and  estimates  can  be  made  on  an  average  per  area  production  basis,  specific 

I  effects  by  land  allocations  are  not  isolated.  We  believe  that  the  harvest 
contribution  foregone  compared  to  full  intensive  management  for  each  special 
land  classification,  as  identified  on  page  124,  should  be  shown.  A  display 
similar  to  what  is  needed  can  be  found  on  page  B-3  of  the  Eastside  Salem  Draft  EIS. 

B)  BUDGET  ANALYSIS.  The  EIS  deals  not  just  with  environmental  effects,  but 
also  with  economic  impacts.  Since  the  harvest  level  will  vary  with  the  amount 

of  funding  that  is  available  this  will  have  a  critical  effect  on  local  economics. 


Mr.  James  Hart 


August  20,  1982 


Mr.  James  Hart 


August  20,  1982 


83-2 


83-3 


On  page  64  of  the  EIS  it  states,  "A  basic  assumption  of  the  analysis  is  that 
sufficient  funding  and  personnel  will  be  available  for  implementation  of  the 
final  decision."  We  feel  that  this  is  an  extremely  weak  assumption  which 
deserves  attention  in  the  Final  EIS.  Blind  acceptance  of  this  assumption  can 
lead  the  reader  into  a  false  feeling  of  security.  Our  concern  is  particularly 
heightened  when  one  notes  that  the  projected  annual  costs  of  intensive  management 
for  the  proposed  action  (page  116)  of  $8,411  million  is  an  increase  of  42  percent 
over  the  current  program  of  $5 - 9  million;  and  further,  that  these  figures  do  not 
include  either  District  or  State  Office  administrative  overhead  which  runs 
several  million  dollars  per  year.     While  the  long  run  projections  appear 
favorable,  we  are   particularly  concerned  with  the  reliability  of  the  assumption 
in  the  first  few  years  of  the  program.  Economically  efficient  harvest  increases 
will  be  especially  important  as  we  work  our  way  out  of  the  current  economic 
conditions.  The  recent  reduction  in  the  annual  sale  programs  at  Medford  and 
other  districts  due  to  budget  constraints  indicates  the  reality  of  our  concern. 

While  the  BLM  cannot  be  expected  to  forecast  the  willingness  of  Congress  to 
approve  budgets,  we  do  believe  that  the  decision  makers  and  the  public  should 
know  the  relative  cost  and  risk  of  various  alternatives.  Therefore,  we  request 
that  the  Final  EIS  display--for  each  al ternative--the  following  information: 

1)  The  average  annual  cost  of  the  intensive  management  program  during  the 
first  decade  with  the  cost  isolated  as  shown  for  the  PA  on  page  116, 
table  B-l. 

2)  The  administrative  and  overhead  costs,  including  an  appropriate  share 
of  State  Office  costs,  such  that  when  added  to  number  1)  above,  it 
will  show  the  total  cost  of  operating  the  district. 

3}  The  "current  situation"  values  for  items  1)  and  2)  above. 

4)  An  analysis  which  would  show  the  sensitivity  of  the  alternative  to 
fluctuations  in  budget  levels.  This  would  basically  begin  at  the 
Q3— 4        harvest  level  proposed  for  each  alternative  and  display  what  the 

harvest  level  would  be  at  reduced  budgets,  in  five  percent  increments, 
until  the  levels  reach  what  you  would  consider  the  minimum  that  could 
be  expected. 

C)  THE  SPOTTED  OWL.  When  the  EIS  states  that  Northern  Spotted  Owl  "...is 
dependent  on  old-growth,  closed-canopy  forests..."  (page  78)  it  reflects  the 
attitude  that  has  polarized  an  important  issue.  For  several  years  Industry  has 
been  urging  the  BLM  and  other  federal  agencies  to  seek  out  more  economically 
efficient  management  strategies  for  providing  for  the  owl.   Instead,  the  agency 
has  continued  to  accept  without  question  the  opinions  of  the  Spotted  Owl 
Committee  which  continues  to  base  its  views  only  on  what  the  owl  appears  to  use 
or  prefer--not  what  it  needs  to  survive. 

Even  though  the  Director's  criteria  clearly  established  the  BLM's  policy  regarding 
the  owl  on  0  &  C  acres,  this  has  not  reduced  Industry's  concern  for  the  bird. 
As  was  pointed  out  by  the  Fish  and  Wildlife  Service  in  their  January  1982, 


83-5 


Status  Review,  the  species  is  not  Threatened  or  Endangered.  Due  to  vast  acres 
of  mature  and  old  growth  on  the  District  it  is  clear  that  opportunity  to  protect 
the  owl  without  reductions  in  timber  harvest  levels  exists  on  the  Roseburg 
District.  The  Draft  EIS  fails  to  recognize  this  fact,  instead  it  indicates  that 
the  owl  may  disappear  completely  in  one  hundred  years  and  states,  "...it  is  not 
possible  to  predict  when  various  pairs  would  have  their  habitat  removed." 
This  dooms-day,  hide-your-head-in-the-sand  approach  must  be  corrected  in  the 
Final  EIS. 

During  the  scoping  process  on  the  District,  I  requested  that  the  BLM  analyze 
the  opportunity  to  maintain  the  owl  habitats  through  each  of  the  first  several 
decades  of  the  planning  horizon.  This  request  was  not  met.  However,  I  believe 
it  is  extremely  important  for  the  public  to  see  and  understand  the  results  of 
such  an  analysis.  We  again  request  that  it  be  included  in  the  Final  EIS.  The 
Final  EIS  should  contain  an  array  which,  beginning  with  current  owl  populations, 
shows  for  each  alternative  and  each  decade  the  number  of  300-acre  habitats  and 
pairs  of  owls  that  can  be  maintained  to  the  end  of  each  decade.  This  should 
be  carried  through  at  least  the  first  four  decades  and  should  not  contain 
replacement  stands.  It  should  not  be  necessary  to  analyze  the  1 ,000-acre  core 
concept  since  the  letter  transmitting  the  proposed  revision  of  the  Spotted  Owl 
Management  Plan  indicated  little  confidence  in  this  figure  and  only  asked  that 
such  allocation  be  maintained  for  a  period  of  five  years.  Clearly,  during  the 
first  decade  of  the  plan  the  District  population  will  not  drop  below  viable 
population  levels  even  if  no  attention  is  given  to  the  owl.  While  the  development 
of  this  array  will  require  many  "best  estimates"  this  should  not  be  a  serious 
concern  considering  that  most  of  the  spotted  owl  policies  today,  and  many  of  the 
outputs  for  other  resources  shown  in  the  EIS,  are  indeed  little  more  than  best 
estimates  by  the  various  specialists.  The  basic  assumption  that  must  be  used 
in  developing  the  array  is  that  the  BLM  would  schedule  harvest  units  in  a  manner 
that  will  maintain  the  greatest  number  of  habitats  for  the  longest  possible  time. 

The  analysis  is  very  important  because  it  will  give  the  public  a  more  realistic 
view  of  the  spotted  owl  issue  and  will  provide  some  idea  as  to  how  much  time  we 
have  to  complete  our  research  and  study. 

Another  important  addition  to  the  EIS  should  be  to  discuss  and  describe  the  owl 
and  old-growth  research  that  is  planned  for  the  next  decade  including  what  will 
be  done  by  the  BLM  and  other  agencies;  and  exactly  what  type  of  information 
will  become  available. 

When  the  Preferred  Land  Use  Alternative  was  presented  to  the  public  for  comment 
in  September  1981,  an  important  concept  was  presented  and  contained  in  the 
statement  on  page  23: 

During  the  planning  period  (the  next  decade)  there  will  be  minimal  impact 
on  habitats  of  the  Roseburg  District. 

IThe  discussion  then  pointed  out  that  it  would  be  four  to  five  decades  before 
the  impacts  might  become  critical.  This  whole  discussion  was  eliminated  from 
the  Draft  EIS.  To  those  of  us  in  the  public  looking  for  rational  solutions 


83-6 


140 


Mr.  James  Hart 


August  20,  1982 


Mr.  James  Hart 


August  20,  1982 


83-8 


839 


83-10 


to  the  problem  of  wildlife  conflicts,  the  exclusion  was  unfortunate.  It  is 
a  common  misconception  by  the  public  that  some  species  of  wildlife  are  about 
to  be  wiped  out  in  the  District.  The  BLM  must  take  the  responsibility  of 
demonstrating  that  the  fears  are  unfounded  and  that  reasonable  wildlife  manage- 
ment policy  is  part  of  the  Bureau's  activities. 

D)  AREAS  OF  CRITICAL  ENVIRONMENTAL  CONCERN  (ACEC's),  The  EIS  is  inadequate 
scussion  of  ACEC's  Fal  Areas  (RNA's).  More  complete 

descriptions  of  the  areas,  why  they  are  considered,  and  the  decision  criteria 
that  will  be  used  should  be  presented.  Before  any  designation  is  final  it  should 
be  demonstrated  that  such  allocations  are  justified  and  the  planned  management 
explained.  In  the  case  of  RNA's  it  should  be  shown  that  the  proposed  areas  are 
the  best  candidates  available  in  the  state  for  the  particular  ecological  unit 
being  protected. 

E)  WILD  AND  SCENIC  RIVERS  (page  27).  The  Final  EIS  should  indicate  which 
rivers  in  the  District  have  been  included  in  the  National  Park  Service  Inventory, 
the  rating  assigned  in  the  Inventory,  and  how  long  the  inclusion  in  the  Inventory 
is  expected  to  restrict  management. 

F)  FORESTRY  PLAN  FOR  OREGON.  The  analysis  of  alternatives  in  terms  of 
compliance  with  the  goals  of  the  Forestry  Plan  for  Oregon  needs  to  be  expanded, 
especially  since  compliance  is  a  criteria  identified  by  the  Director.  The 
analysis  should  not  simply  group  the  alternatives  into  classes  of  consistency 
as  in  table  1-7,  but  should  rank  each  alternative  from  most  consistent  to  least 
consistent.  Where  possible  the  analysis  should  deal  with  quantified  output 
values  to  demonstrate  the  level  of  consistency. 

Another  important  indication  of  the  policy  of  the  State  of  Oregon  regarding  the 
management  of  the  0  S  C  lands  is  House  Memorial  Number  One,  which  was  passed 
„.  ...a  |in  the  last  regular  session  of  the  Oregon  Legislature.  The  Final  EIS  should 
Oo'll  |present  the  Memorial  and  indicate  the  degree  of  compliance  of  each  alternative. 

G)  FACT  VERSUS  OPINION.  There  are  a  number  of  discussions  within  the  EIS 
which  appear  to  be  oriented  at  promoting  particular  viewpoints  about  the  manage- 
ment of  the  BLM  lands  that  are  contrary  to  the  mandates  of  the  0  &  C  Act.  These 
discussions  utilize  "buzz"  words  and  technical  jargon  that  sounds  impressive  to 
the  general  public,  but  actually  contribute  little  to  the  value  of  the  EIS. 
Examples  are  the  discussions  of  old-growth  and  forest  productivity  on  page  42 
and  ecosystem  management  on  page  71.  The  statement  that  the  symbiotic  relation- 
ships in  old-growth  stands  "...may  prove  critical  to  long  term  timber  production., 
is  clearly  a  less  than  professionally  accepted  opinion.  These  discussions 

also  failed  to  draw  the  important  distinction  between  forest  productivity  in 
natural  stands  and  productivity  in  managed  stands. 

H)  NON-TIMBER  BASE  OUTPUTS.  A  major  short-coming  of  the  Draft  EIS  is  that  it 
tends  to  deal  just  with  that  portion  of  the  District  which  meets  the  TPCC 

1  criteria  for  intensive  management.  Non-timber  outputs  from  the  withdrawn  lands 
are  extremely  important  to  the  public  and  should  be  fully  discussed  and  displayed 
in  the  EIS. 


I)  DEPARTURES.  We  are  pleased  that  a  discussion  of  departure  alternatives 
was  included  in  response  to  our  proposal.  While  the  review  was  incomplete 
it  did  indicate  that  opportunities  to  meet  social  needs  may  exist  beyond  the 
rigid  even-flow  concept  while  still  meeting  the  basic  values  of  sustained  yield 
management. 

Ill)  IDENTIFICATION  OF  A  PROPOSED  ACTION 

As  discussed  earlier  it  is  desirable,  if  not  required,  that  the  proposed  action 
be  changed  in  the  Final  EIS.  Since  further  adjustments  will  be  possible  in  the 
decision  process  if  the  analysis  indicates  they  are  needed,  we  can  see  no  reason 
for  the  BLM  to  attempt  to  generate  any  new  alternatives.  Rather,  our  review 
indicates  that  Alternative  2  will  meet  the  requirements  of  the  law  and  the 
criteria  for  management  of  the  western  Oregon  BLM  lands  as  set  out  by  the 
Director.  Alternative  2  should  be  identified  as  the  Proposed  Action  for  evaluation 
in  the  Final  EIS. 

Let  us  look  at  some  of  the  key  criteria  embodied  in  the  0  4  C  Act  and  management 
criteria  in  relationship  to  the  outputs  indicated  for  Alternative  2.  The 
Director  set  out  the  policy  in  seven  specific  criteria: 

Criteron  1 )  Provide  an  optimum  and  non-declining  yield  of  wood  products  to 
enhance  the  economic  stability  of  local  communities  and  industries  while 
providing  for  other  forest  values  as  required  by  law.  Optimum  is  defined  as 
approaching,  meeting,  or  exceeding  the  State  Forestry  Plan  for  Oregon  goals. 

Alternative  2  does  not  fully  meet  this  criterion  in  that  the  land  base  and  harvest 
levels  are  less  than  Alternative  1,  which  conforms  with  the  Forestry  Plan  goals. 
However,  in  order  to  meet  the  other  criteria  Alternative  2  would  appear  reasonably 
optimum. 

Criteria  2  and  3)  Limit  or  exclude  timber  production  to  protect  "...high 
public  recreational  value..."  at  outstanding  sites  and  "...protect  and  maintain 
scenic  quality  in  areas  of  important  visual  value " 

Alternative  2  meets  these  criteria  with  the  allocation  of  8,383  acres  to  visual 
management  and  1,185  acres  for  recreation  management.  This  provides  assurance 
that  key  resource  areas  such  as  the  North  Umpqua  Corridor  are  protected. 

Criterion  4)  Maintaining  water  quality  at  federal  and  state  standards  by 
incorporating  mitigating  measures  in  forest  management. 

Alternative  2  clearly  will  exceed  this  criteron  with,  in  addition  to  mitigation, 
the  assignment  of  over  18,000  acres  to  the  constrained  timber  base  for  riparian 
zone  management. 

Criterion  5)  Management  of  non-timber  forest  values.  The  criteron  provides 

for  allocations,  after  analysis  of  effects;  for  the  protection  of  wetlands-- 

including  riparian  zones--and  providing  habitat  for  Threatened  and  Endangered 
species. 


Mr.  James  Hart 


August  20,  1982 


Response  to  ocmments  in  Letter  83. 


Alternative  2  provides  for  non-timber  values.  The  38,530  acres  of  the  District 
withdrawn  from  the  intensive  timber  base  and  the  24,786  acres  under  constrained 
management  certainly  meet  the  requirements.  Over  6,000  acres  are  provided  to 
protect  the  bald  eagle,  osprey,  and  heron  habitat. 

Criterion  6)  This  criterion  deals  with  additional  allocation  of  commercial 
forestland.  It  prohibits  allocations  "...unless  such  action  is  found  necessary 
to  protect  future  options  for  maintenance  of  serai  stage  distribution  assuring 
continued  high  timber  productivity." 

Alternative  2  clearly  protects  future  options  since  over  140,000  acres  of  mature 
and  old  growth  will  remain  on  the  District  at  the  end  of  the  planning  period; 
thus,  no  such  allocations  are  necessary.  It  may  be  desirable  to  set  out  some 
harvest  scheduling  constraints  for  the  first  decade  to  assure  that  a  proper 
cross-section  of  desirable  units  is  maintained  through  the  decade,  but  this 
would  not  require  withdrawal  from  the  harvest  calculation  base. 

Criterion  7)  This  criterion  urges  maximum  use  of  intensive  management  practices 
to  the  degree  feasible  and  within  economic  efficiency  measures. 

The  effect  of  this  criterion  will  be  shown  from  further  analysis.  The  practices 
with  Alternative  2  meet  this  criterion  as  well--if  not  better--than  the  other 
alternatives. 

In  conclusion,  we  believe  the  next  step  in  the  planning  process  should  be  to 
identify  Alternative  2  as  the  proposed  action  in  the  Final  EIS.  The  analysis 
of  this  alternative  and  application  of  criteria  to  all  alternatives  in  the 
review  will  then  indicate  what  changes  may  be  needed  in  making  a  final  decision. 

Sincerely  yours, 


^'L^i-CvtviA^y  /*ra<pijztA4>{ 


Dennis  Hayward 
Field  Forester 


83-1         See  response  to  ccmmon  issue  4. 

83-2         See  response  to  common  issue  2. 

83-3        Neither  the  O&C  Forest  Resources  Policy  (Appendix  A)  nor  the 

district's  original  planning  criteria  (Appendix  C)   suggest  that  a 
choice  among  alternatives  will  be  based  on  comparative  costs.  Table 
B-l  in  the  FEIS  has  been  expanded  to  show  the  forest  management  costs 
of  Alternatives  4  and  9. 

83-4        See  response  to  comment  69-1. 

83-5         See  response  to  comment  11-8. 

83-6        There  is  a  five-year  research  and  development  program  designed  to 
coordinate  the  research  on  interrelationships  between  wildlife  and 
old  growth  forest  habitat.  Participants  include  the  Bm,  USFS  Pacific 
Northwest  Forest  and  Range  Experiment  Station,  USFS  Regions  5  and  6. 


Robert  Burford,  National   Director,  BLM 
William  Leavell,   State  Director,  BLM 


BLM's  involvement  is  fully  described  in  a  document  titled  "BLM  Role 
in  Old  Growth  Forest/Wildlife  Habitat  Research,  Western  Oregon" 
(available  at  the  Oregon  State  Office). 


141 


BLM  will  provide  financial    and  technical   support  to  the  project  as 
well   as  conduct  some  intensive  studies  and  research.   Objectives  of 
the  old  growth  forest/wildlife  habitat  research  program  are  as 
follows- 

1.  Identify  animal   and  plant  species  dependent  on,  or  which  find 
optimum  habitat   in,  old  growth  forests. 

2.  Describe,  classify,   and   inventory  old  growth  forest 
ecosystems. 

3.  Determine  biological   requirements  and  ecological   relationships 
of  species  found   in  old  growth. 

4.  Evaluate  old  growth  management  alternatives  and  their  economic 

impacts. 

Research  questions  related  to  the  northern  spotted  owl  will   be 
focused  on  objectives  1  and  3,   as  noted  above. 

Details  on  specific  research  projects  are  described  in  the  Action 
Plan  prepared  by  the  Program  leader,  USFS  Pacific  Northwest  Forest 
and  Range  Experiment  Station,  Olympia,  WA. 


83-7         See  response  to  common  issue  1. 

83-8         See  response  to  comment  11-3. 

83-9         The  nationwide  rivers  inventory  (Jan.   1982)   includes  two  rivers 

involving  BLM  lands  in  the  Roseburg  District:   the  North  Umpqua  River 
from  the  Umpqua  National   Forest  boundary  to  Rock  Creek  and  the  Umpqua 
River  from  the  confluence  of  the  North  and  South  Umpquas  downstream 
to  the  Roseburg-Coos  Bay  District  boundary.  No  priority  rating   is 
assigned  in  the  inventory.   Interim  protection  will   be  given  to 
inventoried  rivers  pending  resolution  of  the  Wild  and  Scenic  Rivers 
Act  eligibility  issue.  BLM  efforts  to  determine  Wild  and  Scenic 
Rivers  Act  eligibility  are  expected  to  be  delayed  until   the  next 
planning  cycle. 

83-10       Chapter  1,  Table  1-7  has  been  revised  in  the  FEIS.  Also,   see  response 
to  comments  4-1  and  4-3. 

83-11       The  Oregon  Legislative  Assembly,   1981  Regular  Session,  House  Memorial 
1,    is  included  as  an  attachment  to  Letter  71.  Consistency  with  House 
Memorial   1   is  believed  to  be  the  same  as  consistency  with  Forestry 
Program  for  Oregon  goals  1  and  2,   shown  in  the  EIS,  Chapter  1,  Table 
1-7. 


83-12       Non-timber  outputs  from  the  withdrawn  lands  are  approximated  by  the 
analysis  of  Alternative  1. 


85 


Department  of  Fish  and  Wildlife 

506  SW    MILL  STREET.  PO    BOX  3503,  PORTLAND,  OREGON  97208 


August  20,  1982 


OREGON  DEPARTMENT  OF  FISH  AND  WILDLIFE 

Comments  on 

Bureau  of  Land  Management 

Roseburg  Timber  Management  Environmental  Impact  Statement 

August  20,  1982 

PNRS  820628-068-4 


Mr.  James  E.  Hart 

Roseburg  District  Manager 

Bureau  of  Land  Management 

777  N.W.  Garden  Valley  Boulevard 

Roseburg,  Oregon  97470 

Dear  Mr.  Hart: 

Attached  are  the  Department  of  Fish  and  Wildlife  comments 
on  the  Roseburg  Timber  Management  Draft  Environmental  Impact 
Statement. 

The  Roseburg  BLM  has  the  best  potential  of  any  other  BLM 
district  in  Oregon  to  provide  viable  populations  of  all 
wildlife  species  found  on  the  district.   It  is  unfortunate 
that  the  proposed  action  does  not  make  that  provision.  Of 
greatest  concern  is  the  loss  of  cavity  nesting  habitat, 
and  less  protection  of  northern  spotted  owls  than  the 
minimum  number  recommended  by  both  the  Oregon  Spotted 
Owl  Management  Plan  and  the  Roseburg  BLM  Advisory  Board. 

We  are  also  concerned  with  soil  erosion, debris  avalanches 
and  stream  sedimentation  that  will  result  in  degraded  fish 
habitat  when  natural  production  of  anadromous  fish  has 
been  in  increasing  jeopardy. 

I  would  like  to  support  your  proposed  plan  but  cannot  endorse 
a  land  use  plan  that  does  not  at  least  maintain  viable 
populations  of  all  existing  species  of  wildlife.   I 
urge  your  proposed  plan  be  altered  to  provide  for  those  needs. 


85-1 


85-2 


incerel 


-k 


f r 


(^  j/hn  R.    Donaldson,    PhD 
"Director 


85-3 


After  staff  review  of  the  draft  EIS,  we  would  like  to  see  the  following  items 
clarified  or  addressed  in  the  final  EIS.  The  items  are  of  significant  concern 
to  the  Department. 

General   Comments 

Mining  - 

We  are  aware  that  the  plan  is  a  timber  management  plan,  but  we  are  also  concerned 
with  the  impacts  of  mining  on  Roseburg  District  lands.  Mining  has  had  severe 
adverse  impacts  on  the  fish  resources  of  the  area  and  adequate  control  must  be 
exerted  if  full  use  of  both  fish  and  mineral  resources  is  to  be  realized.  We 
trust  that  the  FEIS  will  address  mineral  resources,  and  the  measures  that  the 
BLM  will  take  to  protect  fish  resources  during  mineral  exploration  and  development. 

Mitigation  of  Impacts  - 

I  We  mentioned  in  our  input  dated  February  5,  1981  and  June  12,  1981  that  the  impacts 
of  other  resource  development  can  be  mitigated.   Expected  mitigative  techniques 
need  to  be  clearly  outlined  in  the  Alternatives.  Snags,  dead  and  downed 
material  are  wildlife  habitats  that  can  be  provided  during  timber  harvest 
operations.  Herbicide  applications  can  have  adverse  impact  on  forage  production 
for  big  game  but  the  impacts  can  be  mitigated  by  considering  the  supply  of 
forage  nearby  and  applying  herbicide  on  a  portion  of  the  treatment  area  if 
forage  is  in  short  supply.  Road  closures  can  prevent  harrassment  of  big  game 
where  necessary.  These  are  examples  of  mitigative  techniques  that  can  be 
provided  regardless  of  the  alternative  selected. 

Maintenance  of  Viable  Populations  of  Wildlife  - 

According  to  the  DEIS  only  Alternative  8,  if  implemented,  will  maintain  viable 
populations  of  indigenous  species.  The  Department  cannot  endorse  any  proposed 
land  use  plan  that  does  not  at  least  maintain  all  existing  populations  of  wildlife. 

Specific  Comments 

Page  4  -  Summary  of  Environmental  Consequences 

Please  clarify  the  paragraph  describing  the  environmental  consequences  on  water 
resources.  That  paragraph  discusses  the  impacts  of  all  alternatives  except  the 
perferred  alternative.   Sediment  yields  would  increase  under  Alternatives  1,3 
and  decrease  under  Alternatives  5  through  8.  What  is  the  expected  impact  of 
the  preferred  alternative  on  sediment  yield?  The  information  supplied  in  the 
EIS  suggests  sediment  yield  would  increase  as  a  result  of  implementing  the 
proposed  action. 


|42  PNRS  820628-068-4 
August  20,   1982 
Page  2. 


PNRS  820628-068-4 
August  20,  1982 
Page  3. 


Alternative  4  states:  "this  Alternative  is  identical  to  Alternative  3  except..., 
and  Alternative  3  will  increase  sediment  yield. 

Analysis  of  impacts  on  water  resources  does  not  include  fish  life  or  animals. 
Under  recreation  there  is  brief  reference  that  fishing  would  be  adversely  im- 
pacted under  Alternative  1,  2,  3  and  5.  Please  quantify  expected  impacts  on 
cold  water  fish. 

o5*4  Page  5.  The  section  on  animals  needs  to  be  expanded  to  discuss  the  impacts  on 
fish.   Increases  in  water  temperature  in  Alternatives  1  and  5  would  negatively 
impact  fish.  The  impacts,  however,  of  implementing  Alternative  4  are  not  dis- 
cussed and  need  to  be  clearly  listed.  The  information  presented  in  the  EIS 
leads  us  to  believe  the  proposed  action  would  adversely  impact  fish.  Sediment 
yield  and  stream  temperature  are  already  limiting  fish  populations  of  Oouglas 
County.  Page  4  of  the  EIS  says  "based  on  the  sample  five  year  sale  plan,  tim- 
ber harvest  activities  planned  in  four  municipal  watersheds  would  increase 
water  yield  and  sedimentation." 

Page  13  and  page  14  discuss  land  classifications  being  managed  by  Roseburg  6LH. 
0  and  C  lands  and  Coos  Bay  Wagon  Road  Grant  lands  are  to  be  administered  by 
the  0  and  C  Act  of  1937  only  where  the  Act  conflicts  with  FLPMA.  Public  domain 
lands,  of  which  18,000  acres  exist  unde'  Roseburg  BLM  jurisdiction  appear  to  be 

I  managed  in  accordance  with  the  0  and  C  Act.  What  is  the  legal  justification 
for  managing  public  domain  lands  under  the  0  and  C  Act  rather  than  under  pro- 
visions of  the  Federal  Land  Policy  and  Management  Act  of  1976? 

Page  24  -  Summary  of  Impacts 

The  environmental  component  category  soils  indicate  that  3,072  acres  per  decade 

I  of  Roseburg  BLM  will  suffer  loss  of  productivity.  Please  explain  how  produc- 
tivity on  5  square  miles  per  decade  can  be  lost  and  still  meet  the  intent  of 
Clean  Water  Act,  Sikes  Act,  FLPMA,  NEPA  and  Executive  Order  11990. 

I  The  summary  of  impacts  lists  expected  changes  in  Roosevelt  Elk  and  northern 
spotted  owl  populations.  The  chart  should  also  indicate  the  changes  in  snag 
dependent  wildlife  and  fish  populations. 

Page  44  -  Terrestrial  Animals 

We  agree  with  the  statement  "of  special  concern  are  snags.  Snags  provide  opti- 
mum habitat  for  33  species  and  are  used,  to  some  extent,  by  47  other  species  of 
birds  and  mammals."  "Recent  snag  surveys  by  district  personnel  revealed  an  av- 
erage of  0.1  snags  per  acre  in  coniferous  forests  less  than  15  years  of  age 
under  BLM  administration."  The  discussion  continues  indicating  the  snags  are 
essential  to  cavity  nesting  birds  and  those  birds  feed  on  insects  and  play  an 
important  part  in  the  control  of  forest  insect  pests.  We  believe  that  the 
maintenance  of  snags  is  important  and  that  the  Bureau  should  take  greater  meas- 
ures to  provide  two  snags  per  acre  on  clearcut  lands  instead  of  0.1  that  are 
presently  existing. 


Page  45  -  Riparian  Habitat 

Riparian  habitat  on  third  order  and  largo 

forest  land  base,  some  of  which  has  been  altered  by  pa'.' 

I  practices  and  is  in  less  than  optimum  condition.  What  would 
allowable  harvest  by  protecting  all  riparian  habitat  on  third  ordi 
instead  of  harvesting  half  the  timber  volume? 

Page  66,  Table  3-2  indicates  the  soil  productivity  win 

miles  of  land  on  the  Roseburg  District  due  to  road  action 

and  landsllding  from  fragile  soils.  More  damage  to  soil  will  result  from 

graveling  and  nutrient  depletion  but  no  data  is  available  to  indicr 

of  damage.  On  page  67  the  discussion  of  water  qua 

i  ;e  by   23  times  the  natural  rote  on  BLM 
to  NEPA,  an  environmental  impact  statement  sho.r 

(reduce  long-term  adverse  environmental  impacts.  What  impacts  on  fish  and  wild- 
life resources  will  result  from  the  loss  of  productivity  of  12  square  miles  of 
BLM  land  and  the  increased  suspended  sediment  yield  from  sluiceouts  and  head- 
wall  fdi lures? 

Page  73  -  Environmental  Consequences,  Timber  Harvest 

The  second  paragraph  of  this  section  briefly  Aev  oposed  modified  area 

control  management  and  the  location  of  habitat  diversity  features  in  a  corridor 
.-[concept.  The  final  EIS  needs  to  show  the  location  and  the  wi  nidified 

85'10l.irpa  control  corridors.   It  is  our  understanding  from  a  meeting  we  had  w 
Bureau  in  1981  that  in  many  places,  particularly  the  southern  portion  ol 
Roseburg  District,  that  the  corridors  appeared  to  avoid  productive  BLM  Lands 
and,  instead,  were  routed  through  private  lands  over  which  the  BLM  has  no  con- 
OC  ^^ltro1-  The  Final  Environmental  Impact  Statement  should  predict  the  effectiveness 
O»3'11lof  these  corridors  and  how  they  tie  in  to  corridors  proposed  by  other  BLM  districts. 

Page  73  -  Timber  Harvest,  Third  Paragraph,  First  Sentence: 

Late  in  the  third  paragraph,  the  statement  made:  "the  loss  in  useable  old- 

I  growth  habitat  is  greater  than  it  appears  in  appendix  F,..."  In  the  final 
impact  statement,  please  indicate  how  great  the  loss  in  useable  old-irowth 
habitat  actually  is. 

Page  74  -  Timber  Harvest,  First  Paragraph,  First  Sentence: 

We  agree  with  the  statement  that  only  Alternatives  6,  7  and  8  will  assure 
the  maintenance  of  viable  populations  on  animals  throughout  the  Roseburg  BLM. 

Page  74  -  Timber  Harvest,  Fourth  Paragraph,  First  Sentence: 

This  paragraph  discusses  the  Tyee  area  and  its  importance  to  elk  that  presently 
exist  in  that  area.  Please  explain  in  the  final  impact  statement  why  there  are 
no  long-term  provisions  for  retaining  mature  or  old-growth  forests  beyond  the 
fourth  decade  in  the  Tyee  area. 


PNRS  820629-068-4 
August  20,  1982 
Page  4. 


PNRS  820628-068-4 
August  20,  1982 
Page  5. 


85 


4 


Pages  74-75  -  Timber  Harvest,  First  Paragraph 

These  two  pages  discuss  the  quantity  of  snags  left  after  timber  harvest  and 
the  importance  of  snags  in  maintaining  viable  populations  of  wildlife  depen- 
dent on  snags.  The  quantity  of  snags  left,  at  today's  rate  of  cut,  (0.1 
snag  per  acre)  is  well  below  that  needed  for  viable  populations  of  dependent 
species.  Two  snags  per  acre  has  been  shown  to  be  the  minimum  number  needed 
to  provide  viable  populations  of  those  species. 

Table  3-10  on  page  75  indicates  the  preferred  Alternative  will  provide  snags 
at  a  level  that  will  depress  the  population  of  snag  dependent  species  to  20- 
30  %  of  potential.  That  level  will  not  maintain  viable  populations  of  those 
species.  Table  3-10  also  indicates  that  Alternative  6  and  7  might  maintain 
viable  populations,  and  only  Alternative  3  would  surely  allow  viable  popula- 
tions to  exist.  It  is  possible  and  desirable  to  leave  snags  during  harvest 
operations.  In  the  final  impact  statement,  please  explain  why  mitigative 
techniques  will  not  be  implemented  that  will  assure  the  continued  existence 
of  snag  dependent  species. 

Page  76  -  Paragraph  Two,  First  Sentence: 

We  agree  that  without  mitigating  prescriptions,  impacts  on  elk  populations 
would  be  more  extensive  than  those  shown  in  Table  3-11,  page  79.  Table  3-11 
is  based  upon  forage-cover  ratios  generally  accepted  by  wildlife  biologists 
in  the  Roseburg  area. 

Page  77  -  Second  Paragraph,  First  Sentence: 

Discussed  are  the  impacts  of  pre-commercial  thinning  on  big  game.  Discussion 
indicates  that  pre-commercial  thinning  can  impede  the  movement  of  big  game  if 
slash  is  unremoved.  According  to  the  DEIS,  slash  will  not  be  removed,  thereby, 
adversely  impacting  big  game.  Please  explain  in  the  final  EIS  why  travel 
lanes  will  not  be  provided  for  big  game  or  why  slash  will  not  be  removed  from 
thinned  areas. 

Page  77  -  Transportation  System,  First  Paragraph,  First  Sentence: 

The  five  year  timber  sale  plan  shows  about  three  miles  of  road  would  be  built 
on  fragile  or  unstable  soils  adjacent  to  streams  with  fishery  values.   If  sedi- 
mentation increases,  the  impacts  would  be  adverse  and  be  significant.  Earlier 
in  the  DEIS,  a  statement  is  made  that  road  construction  does  lead  to  increased 
sedimentation. 


Page  78  -  Fifth  Paragraph,  First  Sentence: 

QC    IPlease  explain  why  the  five  year  timber  sale  plan  has  26  harvest  units  on 
O^-lglunstable  soils  adjacent  to  streams  with  cold  water  fish  values.   It  is  the 
Department's  belief  that  timber  harvest  should  occur  where  fish  habitat  will 
not  be  damaged.  It  is  evident  from  this  paragraph  in  the  EIS  that  timber 
sales  are  planned  in  areas  that  will  prove  harmful  to  fish  resources. 

Page  78  -  Threatened  and  Endangered  Animals 

The  fifth  paragraph  of  this  section  indicates  the  five  year  timber  sale  plan 
will  impact  habitat  of  nearly  one  half  the  known  pairs  of  spotted  owls.  We 
regard  this  loss  as  serious  and  of  Immediate  concern. 

Oregon  Revised  Statute  496.012  says  in  part:  "It  is  the  policy  of  the  State 
of  Oregon  that  wildlife  shall  be  managed  to  provide  the  optimum  recreational 
and  aesthetic  benefits...  in  furtherance  of  this  policy,  the  goals  of  wildlife 
mangement  are:   (1)  To  maintain  all  species  of  wildlife  at  optimum  levels  and 
prevent  the  serious  depletion  of  any  indigenous  species." 

Whether  or  not  old-growth  and  spotted  owl  habitat  has  been  seriously  depleted 
at  this  time  may  be  debated  but  it  is  apparent  that  land  management  continued 
on  a  status  quo  basis  will  seriously  deplete  that  habitat  type  in  the  future. 
The  application  of  State  law  to  federal  land  is  best  addressed  by  the  legal 
profession  but  there  may  be  a  responsibility  of  the  BLM  to  consider  that 
statute  in  formulating  land  use  plans. 


85 


'-14 


Final  impact  statement,  please  quantify  the  impacts  on  fish  that  will 
result  from  building  three  miles  of  road  on  fragile  and  unstable  soils;  also, 
please  justify  those  increases  and  adverse  impacts  in  light  of  the  statement 
on  page  78  that  says:   "increases  in  bottom  sediments,  according  to  Gibbons 
and  Saylo  (1973),  cause  the  most  damage  of  all  factors  affecting  fish  life." 


143 


Response  to  comments   in  Letter  85. 

85-1         This  is  beyond  the  scope  of  the  EIS     which  is  restricted  to  timber 
management     See  response  to  comment  2-1 

85-2         See  response  to  comment  5-3. 

85-3         The  text  has  been  revised  in  the  FEIS. 

85-4         Refer  to  DEIS,  Chapter  3,   page  79, for  impacts  on  fish.  Also,   see 

response  to  comment  74-3. 

85-5         See  response  to  comment  7-1. 

85-6         Refer  to  DEIS,  Chapter  3,  Table  3-2,    for  details.  Most  of  the  loss  is 
due  to  compaction. 

85-7         The  text  has  been  expanded  in  the  FEIS,  Chapter  1-  Table  1-5. 

85-8  Refer  to  Appendix  C,  Table  C-4,  for  comparison  of  riparian  areas. 
None  of  the  alternatives  provides  for  harvesting  half  the  timber 
volume. 


Alternatives  2,   3,  4,   and  7  employ  modified  area  control   (DEIS, 
page  124)    for  the  riparian  zones  along  third  order  and  greater 
streams.  The  sample  five-year  timber  sale  plan,  as  described   in  the 
DEIS,  Impacts  on  Animals  section,   page  75,   indicates  a  yearly  average 
of  12  acres  clearcut  and  96  acres  partial   cut    in  the  above  areas.   If 
these  areas  were  removed  from  the  allowable  cut  calculation,  as  in 
Alternatives  6,   8,   and  9,   an  estimated  decrease  of  500  MCF  or  3  MM 
bd.   ft.  would  occur. 

85-9         The  DEIS  indicates  impacts  are  insignificant.  Also,   see  response  to 
comment  74-3. 

85-10       Maps  are  available  for  inspection  in  the  Roseburg  District  Office. 

85-11       Corridor  alternatives  adopted  or  proposed  by  other  BLM  districts 
which  adjoin  Roseburg  (i.e.,  Coos  Bay  and  Eugene)  have  been 
considered  and  are  coordinated  with  Roseburg  District  alternatives. 
Effectiveness  will  be  monitored  over  time. 

85-12       The  text  has  been  revised  in  the  FEIS,  Chapter  3,  Terrestrial 
Vertebrates,  Timber  Harvest  section. 

85-13       Conflicts  with  operator  safety  requirements  preclude  snags  frcm  being 
left  on  many  harvest  operations  in  the  intensive  forest  management 
base.  Although  options  to  leavirg  snags  exist  (e.g.,  topping  trees), 
those  options  where  the  cut  level  would  be  reduced  to  the  point  of 
changing  an  alternative  would  not  be  planned.  Also,  see  response  to 
comment  5-3. 


85-14       Refer  to  DEIS,  Chapter  3,   page  79  for  impacts  on  fish.  Also,   see 
response  to  comment  74-3 

85-15       Adverse  impacts  can  be  mitigated  through  project  design  features,    as 
described   in  DEIS,  Chapter  1. 


SEATTLE,      WASHINGTON      98101 


U.S.      ENVIRONMENTAL     PROTECTION     AGENCY 
<(eo  st^  R  E  G  t  O  N     X 

v,        ^^        r  1200      SIXTH      AVENUE 

"two?  m/S  443 

32 


86 


86-1 


James  E.  Hart,  Oi strict  Manager 
Roseburg  District  Office 
Bureau  of  Land  Management 
777  NW  Garden  Valley  Blvd 
Roseburg,  OR     97470 

RE:     Roseburg  Timber  Management  Program  DEIS 

Dear  Mr.   Hart: 

The  Environmental  Protection  Agency  (EPA)  has  completed  reviewing  the  DEIS 
for  the  Roseburg  Timber  Management  Program  (TMP).  The  DEIS  adequately 
presents  the  program  and  the  various  alternatives  available  for  its 
implementation. 

We  would  like  to  offer  the  following  comments  on  Chapter  3  (ENVIRONMENTAL 
CONSEQUENCES)  which  may  serve  to  improve  the  discussion  in  the  Final  EIS. 

Checkerboard  Lands  Pattern 

Lands  under  8LM  management,  in  the  Roseburg  District  as  well  as  other 
western  Oregon  districts,  are  largely  in  a  checkerboard  pattern.  The  map 
accompanying  the  DEIS  shows  these  lands  to  be  widely  dispersed  in  a 
"circle"  surrounding  Roseburg.  This  land  distribution  pattern  creates 
special  problems  for  managing  the  environmental  consequences  of  the 
TMP  when  both  the  causes  and  the  mitigating  measures  constantly  cross  and 
recross  the  boundaries  of  BLM  lands.  Any  special  limitations  and  controls 
to  address  this  problem  should  be  described  in  the  Final  EIS.   It  would 
also  be  helpful  if  the  Final  EIS  noted  any  cooperative  arrangements  or 
joint  actions  being  undertaken  with  adjacent  land  owners  for  managing  the 
boundary-crossing  environmental  consequences  of  the  management  program. 


144 


Air  quality 

We  cannot   locate  the  reference  to  a  30-35  mile  distance  for  slash  burn 
plume  dispersion,   beyond  which  "(p)ollutants   ...   dre  usually  mixed  by  wind 
and  dissipated..."   (citing  EPA,    1978).     The  report  cited   indicates  that  a 
100  mile  distance  is  a  more  appropriate  measure  to  evaluate  plume  disper- 
sion and  potential  effects  on  Class  I  and  non-attainment  areas.     There  are 
four  Class   I   areas  (Diamond  Peaks,   Three  Sisters  and  Kalmiopsis  Wilderness 
*    _    Areas,   and  Crater  Lake  National  Park)   and  two  non-attainment   areas   (Medford 
OD"t    and  Eugene)  within   100  miles  of   the  Roseburg  District   lands.     The  final  E1S 
should  discuss  and  evaluate  the  potential  effects  of  slash  burning  on  air 
quality  in  these  Class  1  and  non-attainment  areas  and  indicate  appropriate 
smoke  control  measures  to  avoid  smoke   intrusions   in  these  areas. 

We  recommend  that  you  consult  with  the  Oregon  DEQ  for  current  data  about 
particulate  emissions  from  slash  burns  and  for  assistance  in  quantifying 
the  effects  of  slash  burns. 

The  OEIS  does  not  discuss  potential  alternatives  to  slash  burning  which 
may  provide  viable  air  quality  control  measures.     Various  post-harvest 
management   techniques  should  be  included  in  the  discussion  of  air  quality 
management,   or   this  section  should  reference  other  parts  of  the  EIS  where 
they  may  be  discussed. 

Human  Health  Effects  &  Potable  Water  Supplies 

I  Page  86  of   the  DEIS   indicates  that  the  "...number  of  people  that  could  be 
86" 41  directly  affected  by  herbicide  application  in   the  planning  area  is  small," 
I  but  presents  no  demographic  or   land  user  data  to  support  this  point.     We 

recommend   that  quantitative  information  be  provided  to  support  this  conclu- 
I  sion.     This  discussion  should  include  an  assessment  of  possible  herbicide 
OD-5|  accumulation   in  drinking  water  supplies   [the  DEIS   (p.  69)   notes  four 

I  municipal  watersheds  on  BLM   lands].     The  FEIS  should   indicate  whether  the 
oe_C|  'MP  will   cause  or  contribute  to  any  violations  of  the  Interim  Primary 
OD~0|  Drinking  Water  Regulations  in  the   affected  water  supplies. 

I  The  final  EIS  should  discuss  and  evaluate  alternative  vegetation  manage- 
ment techniques,   such   as  on-ground  spraying  or   hand  cutting,  which  may 
minimize  unwanted  environmental   consequences  of  aerial   spraying. 

Finally,  we  recommend  that  you  coordinate  this  part  of  the  EIS  with  the 
work  now  being  done  through  the  Salem  District  Office  to  prepare  a  DEIS 
for  BLM's  Westside  (Oregon)  vegetation  management  program. 


Water  quality 

Page  69  of  the  DEIS   indicates  that  buffer   strips  are  expected  to  minimize 
herbicide  drift  or  accidental    spraying  of  water  courses.     However,   Table 
3-5  shows  varying   amounts  of   timber  harvesting  will   take  place  In  bill 
strips.     The  two  alternatives  which  Include  no  harvesting  In  buffer  strips 
show  that  sedimentation  can  be  reduced  by  approximately  150,000  tons  over 

I  the  first  decade  of   the  program.     This  apparent  contradiction  should  be 
clarified,   showing   any  relations  between  extent  of  spraying   in  areas 
around  streams,  and   the  amount  of  buffer  strip  harvesting. 

Tables  2-5   (p.   39)   and  2-7   (p.  41)  seem  to  Indicate  that  most  major 
streams  within   the  Roseburg  District  suffer  from  severe  sedimentation 
problems.     Timber  harvesting  within  the  District  will  exacerbate  this 
problem.     The  DEIS  recognizes   this  situation  but   is  unclear  about  measures 
which  may  be  implemented  to  minimize  sedimentation  and  to  meet  and 
maintain  water  quality  standards.     One  control  which  appears  viable  is  to 
preserve,   or  widen  as  appropriate,   streamside  buffer  strips.     Table  3-5 
(p.  68)   indicates   that  extensive  cuts  are  to  be  made  in  existing  buffer 

I  strips.     We  recommend  that  these  buffer   strips   not  be  cut,   and  that  the 
Final   EIS  identify  and  evaluate  potential  mitigation  measures  which  could 
be  used  to  reduce  the  sedimentation  problems   identified   in  the  Draft  EIS. 
.  —  I  It  should  also  indicate  whether  the  streams  currently  meet  the  applicable 
86   10lwater  quality  standards  and  how  each  of  the   alternative   timber  management 
^programs  would  affect  water  quality  standards  compliance. 

EPA  has  rated  this  EIS  10-2  [LO:   Lack  of  Objection;   2:    Insufficient   Infor- 
mation].    We  appreciate  the  opportunity  to  review  the  report.     Should  you 
desire  to  discuss  EPA's  suggestions,   you  may  contact  Mr.   Dick  Thiel,   our 
Environmental   Evaluation  Branch  Chief,  at   (FTS)  399-1728  or   (206)  442-1728. 


y£ 


Sincerely, 


V-  John  R.   Spencer, 

Regional  Adminstrator 


Response  to  comments   in  Letter  86. 

86-1         The  DEIS,  Chapter  1,  describes  Memoranda  of  Understanding, 

Cooperative  Agreements,   Permits  and  other  instruments  appropriate  for 
managing  the  intermingled  ownership  pattern  of  the  O&C  lands.  Also, 
see  response  to  comments  4-4,   5-3,   and  58-3. 

86-2         The  text  has  been  revised  in  the  FEIS,  Chapter  3,  Impacts  on  Air 
Quality  section. 

86-3         Alternatives  to  slash  burning  and  other  related  issues  will  be 

addressed  in  an  EIS  on  Vegetation  Management  for  western  Oregon.  The 
Draft  EIS  is  being  prepared  and  is  expected  to  be  published  later  in 
1983. 


86-6         The  timber  management  plan  is  not  expected  to  result   in  violations  of 
the  Interim  Primary  Drinking  Water  Regulations.  BLM  cooperates  with 
the  Oregon  Department  of  Environmental  Quality  as  well   as  the 
affected  municipalities  through  Memoranda  of  Understanding,   as 
described  in  the  DEIS,  Chapter  1,  pages  27-29. 

BLM  timber  harvesting,   road  construction,  chemical   applications, 
slash  disposal  and  reforestation  requirements  meet  or  exceed  the 
Oregon  Forest  Practices  Act  standards,   as  indicated  on  page  27  of  the 
DEIS. 

86-7         Alternative  7  in  the  DEIS  evaluates  this  point.  The  new  EIS  on 

Vegetation  Management  will  specifically  address  a  no  aerial   spray 
alternative. 


As  part  of  BLM's  planning  process  a  determination  of  the  number  of 
residences  within  1/2  mile  of  BLM  land  was  made.  Approximately  9,600 
rural   residences  are  within  the  boundaries  of  the  Roseburg  District. 
Of  these  3,413  or  36  percent  are  within  1/2  mile  of  BLM  land.  Only  a 
few  percent  are  affected  in  any  given  year.  These  are  detailed  in 
site  specific  environmental    assessments  prepared  for  vegetation 
management  and  other  projects. 

This  issue  was  addressed  in  the  FEIS,  Vegetation  Management  with 
Herbicides:  Western  Oregon  1978  through  1987.   Refer  to  DEIS,  Chapter 
1,  page  20,  which  incorporates  the  above  FEIS  by  reference.   In 
addition,  the  new  EIS  on  Vegetation  Management  will   address  the 
issue. 


86-8         Streamside  buffers  for  water  quality  protection  during  timber 

harvesting  operations  are  different  from  those  streamside  buffers 
associated  with  herbicide  spraying.  The  EIS,    in  Appendix  C,  Table 
C-4,    identifies  protective  measures  proposed  during  timber  harvest 
operations  along  streams  (riparian  zones).  Protective  stream  buffers 
applied  during  herbicide  spraying  operations  are  identified   in  the 
DEIS,  Chapter  1,  page  22,   Plantation  Maintenance  and  Release  section. 

86-9         Alternatives  6,   8,   and  9  do  not  include  any  harvest  within  buffer 

strips.  Mitigation  is  described   in  DEIS,  Chapter  1.  See  response  to 
comment  5-3. 

86-10       See  response  to  comment  15-6. 


90 


145 


/Kvj\\  United  States 
UUkI//  Department  ot 
\»A/  Agriculture 


Pacific 
Northwest 
Region 


319  S.W.  Pine 
P.  0.  Box  3623 
Portland,  OR 32208. 


1950 

August  20,  1982 


Mr.  James  E.  Hart,  District  Manager 
Rojeburg  District  Office 
777  N.W.  Garden  Valley  Blvd. 
Roseburg,  OR  97470 


Dear  Mr.  Hart: 

We  appreciate  this  opportunity  to  comment  on  the  Roseburg  Timber 
Management  Draft  Environmental  Impact  Statement.  The  Umpqua  National 
Forest  and  Roseburg  District  are  linked  by  several  mutual  management 
concerns  and  the  opportunity  to  address  them.  There  is  also  a  shared 
opportunity  to  be  responsive  to  the  public  in  the  management  of  resources 
which  seek  habitat  rather  than  heed  administrative  boundaries. 
Significant  among  these  are  elk  and  northern  spotted  owl,  the  latter 
being  inextricably  linked  to  old-growth  forests. 

We  are  concerned  that,  though  there  has  been  much  coordination  between 
Forest  and  Bureau  of  Land  Management  Roseburg  District  personnel,  the 
proposed  action  does  not  reflect  this  coordination  or  recognize  that 
certain  decisions  about  District  management  affect  resource  management  on 
the  Umpqua  National  Forest. 

The  number  of  northern  spotted  owl  pairs  recommended  for  testing  in  the 
Umpqua  National  Forest  planning  process  is  based  on  the  Oregon 
1  Interagency  Spotted  Owl  Management  Plan.  Roseburg's  proposal  to  not 
90  ilmana9e  in  accordance  with  recommendations  of  that  plan  may  have 
I  impl i cations  on  the  number  recommended  for  the  Umpqua. 


90-2| 


Similarly,  the  District's  planned  reduction  in  elk  habitat  could  place  a 
burden  on  National  Forest  habitat  resources.  We  would  like  to  have  these 
implications  considered  in  your  decision. 

We  also  have  an  interest  in  methods  of  analysis  you  have  used  which  may 
be  applicable  to  National  Forests  and  add  consistency  to  our  planning. 
Of  particular  interest  are  estimation  techniques  used  in  assessing  water 
resource  effects  and  your  rationale  linking  mitigation  provisions  of  the 
several  alternatives  and  Federal  law. 


Mr.  James  E.  Hart 


Another  area  of  concern  is  the  timber  growth  prediction  attributed  to 
fertilization  as  it  may  be  interpreted  to  apply  on  National  Forest 
lands.  Although  we  agree  that  this  practice  can  increase  yields  we  have 
little  information  on  response  from  the  Umpqua  National  Forest.  Umpqua 
yield  tables,  therefore,  are   necessarily  more  conservative. 

We  look  forward  to  continued  close  cooperation  with  the  Roseburg  District 
in  formulating  the  Umpqua  Forest  plan.  Together,  the  two  plans  will 
provide  the  major  thrust  for  Federal  land  management  in  the  next  decade 
in  Douglas  County. 


Sincerely, 


^*£. 


EFF  M.  SIRMON 
Regional  Forester 


FS-62CO-1 1  (8-80) 


91 


Response  to  comments  in  Letter  90. 

90-1         The  text  has  been  revised  in  the  FEIS,  Chapter  3,   Impacts  on  Animals 
section,   indicating  that  if  BUI  does  not  manage  for  the  number  of 
pairs  allocated  to  it   in  the  Spotted  Owl  Management  Plan,   the  unmet 
portion  would  revert  to  the  Oregon  Endangered  Species  Task  Force  to 
consider  possible  reapportionment. 


INDUSTRIAL  FORESTRY  ASSOCIATION 


2680  NO  PACIFIC  HIGHWAY 
MEDFORD.  OREGON  97501 


-.11    u     t 


90-2         The  text  has  been  revised   in  the  FEIS,  Chapter  3,   Impacts  on  Animals 
section. 


91-1 


91  2 


James  E.  Hart,  District  Man 
Bureau  of  Land  Management 
777  NW  Garden  Valley  Roulevard 
Roseburg,  Oregon   97470 

Dear  Jim, 

I  am  Southwest  Oregon  Di 
located  in  Med ford  at  2680  North  Paci  fie  Highway . 
about  90  timber  industry  comj 
which  purchase  timber  on  the  Roseburg  mil  District. 

I  would  like  to  thank  the  BLM  for  t1' 
the  adequacy  of  the  Roseburg  Disl 
attempt  to  predict  environmental  impacts  resu 
actions.  The  interdisciplinary 
efforts. 

in  extensive  effort,  however,  i 
as  a  guide  to  decision  makers.   Sever.il  are 
leading  and  may  confuse  decision  make] 
hensive  timber  management  plan  which  will  I 
of  the  Roseburg  study  area. 

To  begin  with  the  analysis  of  the  cui  : 
adequate.   Comparing  it  with  the  other  seven  alternatives  is  liki 
apples  and  oranges.   Alternative  b   use: .  the  old  stand  i 
and  yield  data,  while  the  other 
native  3  were  chosen  as  the  basic,  of  the  future  t 
assume  you  would  use  the  new  invi 
now  proven  to  be  incorrect.   Alt, 


now  proven  to  De  incorrect,  ttitern 
using  the  new  inventoi 
compare  all  eight  alternatives.  II  |ust 
Alternative  (#4)  is  actually  a  proposed 
Roseburg  BLM  District. 

Another  unclear  and  misle 
Page  23  indicates  the  greatest  habitat  modil 
5.   On  page  24,  table  I 
modification.   Table  1-5 

to  a  greater  extent  than  Alternative  1,  even 
acres  than  Alternative  1  and  prt  ut . 


146 


James  f . 
Page  2 


Hnrt ,  Di 


James  I 
Page  3 


913 


:   .  ■  ■  : 

il  will 

■ 

■  ■■ 
■ 

i  sm  or 

■ 
■ 

Bed  on  t  .i  1 1 

Ibro;ni  No  ment ion 

15  made  i  on  for 

cavit  locument,  de- 

cadent, sna  considered  estheti        ng.  An 

attempt  should  be  made  in  tin  ,  of  impacts 

relat  ii  ■ 

On  pages  60,  61  ,  toil  62  an  atti  I  o  desci  ibe  the  economic 

of  t  i  ient  on  Local  econi  i        n,  In  this  in  IS,  the  data  i 

sented  in  1976-1978  dollars,  for  I1  n't  understand  how 

predirt  Spotted  Owl  population  levels  i"  fin-  tOth  decade,  yet  we  can'l 
economic  discussion  presented  in  current  dollar  values.   It  seems  to  me  m 
current  economic  data  would  be  more  meaningful  to  a  decision  maker.   In  the  n  !'■ 
it  would  he  helpful  to  know  if  the  figure-,  in  Table  2-26  (Economic  Affects  of 
I  isheries,  Hunting,  and  Recreation)  and  the  summary  on  page  62  are  also  in  1976- 
1978  dollars. 


91  5 


In  addition  to  the  above  general  thoughts,  which  I  presented  in  oral  testi- 
mony at  the  August  18th  public  hearing,  I  would  like  to  add  the  following  more 
specific  concerns  and  recommendations  for  your  consideration  in  evaluating  the 
adeguacy  of  the  DEIS. 

1.  Alternal  ,  Linkage  to  the  new  policy  on  BLM  0&[  Lands, 
Onl)  alternatives  1  and  to  determining  harvest  based  on 

1 i mi  ted  landbase  withdrawals  for  other  resources. 

IRecommendat i ons :   All  alternatives  should  be  redeveloped  based  on  the  new  BLM 
planning  criteria.   If  necessary,  a  new  proposed  action  should  be  developed 
either  in  the  final  EIS  or  a  new  Drat! 

2.  Departurealternatives,  '[though  actually  calculated,  were  given  essent- 
ially footnote  coverage  in  the  DEIS.  NEPA  requires  the  agency  to  fully 

1 1  ill  alternatives  even  if  they  violate  current  law  or  policy.  The 
description  in  the  EIS  that  the  departure  analysis  is  not  "useful  enough" 
te.   It  is  obvious  that  significant  increases  in  current  and 
md  growth  is  possible  with  a  departure  as  compared  to 
the  pro; 


^-  —  I  Recommendations:   fully  analyze  several  v 
y  |—  *  |socioeconomital  and  environmental  effects 


able  departure 
in  the  FEIS. 


.1  ternat lves  for  their 


91-8 


I 
under  the  A.C.E.  corn  i  , 
at  ion  valu 

■ 

uea  only  gi vi 

■ 
value  of  the  land.   I 
is  worth  when  sold  in  the  market  p 

mkings.   One  question  wi 

higher  S.E.V.  regimes,  why  was  the  Li 
the  preferred  alternal 

IThe  price  assumptions  are  overly  optimistic  interims  of  futun 
it  ,  the  current  price  is  about  one-h  i 
for  timber  values  also  appear  to  be  overly 

„«/>|^'  "1(  cos*-  factors 
9l~*10|   '  l  than  has  been  recent  ex;. 

|on  Industry  lands,  or  (2  tiated. 

Recommendation:  Completely  redo  the  economic  analysis  to  reflect  the  true  cur- 
rent costs  and  revenues  generated  by  management  and  evaluate  returns  exclusive 
of  the  ACE  effect. 

5.   We  are  extremely  concerned  at  the  BLMS  proposal  to  reduce  the  landbase 
by  some  44,000  acres,  increase  the  management  intensity  through  higher  bud- 
get dollars,  and  thereby  mere  i.  While  we 
approve  strongly  of  intei               'ment  and  the  leadei 
shows  in  this  area,  we  are  concerned  about  the  use  of  intensive  management 
to  trade  away  acres  for  unsubstantiated  other  resource  use3.  The  increase 
in  budgets  required  to  be  successful  m  this  program  will  likely  not  be 
there  in  the  future.  Thi                          entire  timber  pro- 
gram predicated  on  some  very  shaky  i               r>s.  One  solution  to 
the  dilema  is  to  alter  the  forest  management  intensity  to  reflect  better 
budget  expectations  and  make  up  the  loss  in  production  from  additional  al- 
locations of  timberland  from  nontimbei 

I  Recommendation:   Reformulate  the  alternatives  into  proposed  programs  which  are 
more  in  line  with  realistic  budget  assumptions,  and  clearly  display  what  the 
increases  in  budgets  expected  are  for  each  increment  of  additional  allowable 


Sincerely  yours, 


D  i   r>K-.^rl   U     C~  1 -l~ .•  ' 


Richard  H.    Felgenhou 
District   forester 


Response  to  comments   in  Letter  91 

91-1         Council   on  Environmental  Quality  {CBQ)   Regulations  (40  CFR 

1502.14(d))   require  a  No  Action  Alternative  to  be  included  in 
environmental    impact  analysis. 


91-6         The  FEIS  includes  a  new  Preferred  Alternative  (Alternative  9). 
Also,  see  response  to  comment  12-1. 

91-7         Refer  to  Appendix  B,  Results  of  Scoping.  Also,   see  response  to 
comment  78-4 . 


91-2         The  text  has  been  revised   in  the  FEIS,  Chapter  1,  Comparison  of 

Impacts.  Differences  relating  to  the  amount  of  old  growth  existing  at 
the  end  of  the  first  decade  under  Alternatives  1  and  5  are  explained 
in  the  DEIS,  Chapter  3.  Table  3-8. 

91-3         See  response  to  common  issue  1. 

91-4         Although  positive  effects  on  cavity  dweller  habitat  would  result  from 
herbicide  treatment  to  broadleaf  species,  such  treatment  would  not 
provide  significant  wildlife  benefits  due  to  the  scattered 
distribution  of  broadleaf  species  in  the  Roseburg  District. 


91-8         See  response  to  comment  68-19. 

91-9         Average  sales  value  per  M  bd.   ft.   for  timber  sold  by  the  Roseburg 

District  was  $260  in  FY  1981  and  S94   in  FY  1982.  These  baselines  have 
been  added  to  Appendix  B,  Table  B-2. 

91-10       See  response  to  common  issue  5. 

91-11       See  response  to  common  issue  2. 


91-5         Table  2-26  has  been  revised   in  the  FEIS  to  include  a  footnote  which 
indicates  that  the  estimates  of  personal  earnings  reported  are 
adjusted  to  the  average  wage  and  price  level  which  prevailed   in 
Oregon  between  1976  and  1978.   In  order  to  sum  the  results  of  Tables 
2-25  and  2-26  (page  62,  DEIS)  the  estimates  of  personal   earning  must 
be  in  dollars  of  the  same  period.  The  most  recent  year  in  which  data 
were  available  for  all  resource  categories  evaluated  in  the  plan  was 
1978. 


93 


147 


984  Lincoln 
Eugene,  Ore.  97401 


Roseburg  District  Manager 
Roseburg  District  Office 
777  N.W.  Garden  Valley  Blvd. 
Roseburg,  Ore.  97470 


Following  are  my  Garments  on  the  Roseburg  Timber  Management  Environmental 
Impact  Statement. 

I  am  continually  appalled  tl^at  the  BLM  could  write  an  EIS  so  curiously 
descriptive  and  graphic  concerning  the  impacts  to  wildlife,  and  yet  propose 
to  make  those  very  decisions  having  the  worst  effect.  The  EIS  admits  that 
continuing  timber  management  at  Uae  proposed  level  will  ruin  forest  diversity; 
that  elk  survival  cover  will  be  greatly  reduced,  leading  to  a  20%  decline  in 
the  population;  that  mortality  salvage  will  eliminate  snags;  that  the  preferred 
alternative  will  cause  a  34%  decline  in  old  growth  after  one  decade,  and  a 
ridiculous  71%  decline  after  a  century;  that  the  Tyee  area  contains  none  of  the 
old  growth  management,  et  cetera. 

It  defies  comprehension  for  the  Roseburg  District  to  say  that  the  spotted 
owl  is  a  potential  candidate  for  threatened  and  endangered  status,  yet  propose 
an  alternative  that  does  not  aid  its  long  term  cliances  for  survival.  Likewise 
with  clioosing  an  alternative  that  follows  tlie  Forestry  Plan  for  Oregon,  but 
does  not  follow  the  Oregon  Department  of  Fish  and  Wildlife  recommendations. 

Nothing  in  the  O&C  Act  requires  this  sort  of  donu-nant  use.  It  is  especially 
ridiculous  to  raise  the  allowable  cut  when,  due  to  the  deep  recession,  billions 
of  BLM  board  feet  are  sold  but  not  yet  cut.  Simply  selling  more  will  only  further 


93-1 


depress  an  already  disastrous  market. 

When  will  foresters  realize  that  wildlife  and  tunber  management  are  not 
separate  disciplines;  tliat  both  rest,  and 

tliat  it  is  not  good  enough  to  consign  wildlife  to  the 
inant  timber  program.  The  excuse  has  always  been  the  O&C 
does  not  mention  wildlife,  BLM  need  not  worry  about 
attitude.  Forest  management  is  not  synonymous  with  timber  management. 

Tlie  O&C  Act  does  mention  watershed  management.  Amajor  c 
management  is  riparian  zone  preservation,  which  fares  rather  .  ■ 
preferred  alternative.  It  is  the  first  and  second  order  streams,  the  beginnings 
of  the  major  rivers,  whose  riparian  areas  are  not  being  protected  at  all. 

The  EIS,  like  many  of  its  ilk,  goes  into  gruesome  detail  on  wildol 
which  is  laudatory.  But  it  never  explains  the  forestry  program  in  hurt;.' 
It  is  not  necessary  to  include  a  detailed  and  complicated  analysis  of 
allowable  cut's  derivation.  But  it  is  important  to  explain  truthfully  how  the 
allowable  cut  is  derived;  the  use  of  the  allowable  cut  effect;  and  the  rationale 
for  the  allowable  cut.  Itone  of  these  things  are  done.  There  is  no  explana- 
tion for  why  tlie  cut  goes  up  so  highly  in  this  EIS. 

In  light  of  the  fact  that  nutters  are  not  settled  on  Coos  Bay,  and  that  a 
corridor  system  may  be  the  only  viable  way  to  settle  the  remaining  old  growth 
into  a  workable  system,  I  shoula  think  it  liastyi  to  espouse  an  alterr^ 
like  this  one. 

Sincerely, 

Cameron  La  Follette 


Response  to  comments  in  Letter  93. 


93-1    The  text  has  been  revised  in  the  FEIS,  Appendix  C,  by  the  addition  of 
Figure  C-2.  Also,  see  response  to  comment  16-40. 


94 


UNITED    STATES    DEPARTMENT    Of    COMfVlf  RCf 
Nation.il  Oceanic  and  Atmosphc 


September  17,  1982 


District  Manager 
Bureau  of  Land  Management 
Department  of  the  Interior 
777  NW  Garden  View 
Roseburg  Boulevard 
Roseburg,  Oregon  97470 

Dear  Sir: 

This  is  in  reference  to  your  draff  envii 
entitled  "Roseburg  Timber  Managenent."  The  ei 
National  Oceanic  and  Atmospheric  Administration  are 
consideration. 

Thank  you  for  giving  us  an  op; 
which  we  hope  will  he  of  assistance  to  you.  We  would  d| 
four  copies  of  the  final  environmental  impacl 

Sincerely, 


Joyce  M.  Wood 
Director 
Office  ol 


Enclosure:  Memo  from:  Dale  R.  Evans 

National  Marine  Fisheries 


^ 


148 


UNITED  STATES  DEPARTMENT  OF  COMMERCE 
National  Oceanic  and  Atmospheric  Administration 


, 


if- 


Sub;. 
cor.: 

The 
doc 

COUl-i  :rces. 

ut   could  ent.  in 

For  caused  by    lai 

■    order 

total  of  ton  :.r  of  the  soi  seburg 

SYUs  are  (  I  md  Problem  soils  (Table  2-4) ,  i 

In  other  cases,  a  small 

is  dam  could  block  access  to  all  ■  liomous 

tal  i       roi      i         to  I 
;ent  document. 

Specific  O  : 

-..      .1  Animals.   There  is  no  mention  of  possil  of  the 

y^T_l  posed  action  would  increase  water  yield 

'  rsheds,  there  must  be  some  impact  on  fish. 


Q4-OI  Ic  1-5.   Summary  of  Imp 

^"  ^1  ts  en  fish  habitat. 


The  table  does  not  include  an 


Pa1e  26-   Federal  Agenel.- 


94-3 


94-4 


94-5 


response 

md  anadtomou 

Resour  he  Coastal  Zoi 

Environ  ind  makes  recoi 

Il  DIBOUS  f  ish*-r  .n  ana> 

Wildlife  Coordination  Act. 


Soils.   Table  2-4,  Fragile  and  Problem  Soil- . 


Pages  34-36 

to  Figure  2-2,  •  .  Qf  the  table  and  I 

correspond,  even  considering  the  < 

compare  and 


age  46,  Table  2-11 


_  Salmonid  Fish  Habitat  and  Papula*:  i 
i  'ual  miles  of  fish  habitat.   Some  habil 


by  more  than  om 
year. 


94-6 


im  and  downstr 

r  quality  and  quant 
:  for  fish  mig ratioi 
should  i  :.   impact  on  fish  caused  by  the  propos< 

quant i : 

I  Page  77.  Fish.  Whi 
and  the  section  on  ; 
the  consequent  i  .rious  altern. 

discussed. 


larly  concerned  for  the  n 
buffer  strips  tor  streams.   We  strongly  urge  inc 
action  (or  into  whichever  alternative  ii 
provide  for  protection  and  enhancement  of  fish  i 


integrity  oi  I 

the  proposed 

which 
irea. 


11 


I  Special  attention  should  be  given  to  bank  protection  on  first  and  second  order 
as  well  as  higher  order  streams  to  prevent  sed 
protection  for  all  Class  I  streams  against  sedimentation  and  in-.- 
temperatures. 

Inasmuch  as  future  declines  in  timber  auppli  61),  it 

would  seem  prudent  to  protect  alternative  economic  resources  as  much 
possible. 


^^^ 


Response  to  comments   in  Letter  94 

94-1         See  response  to  comment  74-3 

94-2  See  response   to   comment   74-3. 

94-3         Tiie  text  has  been  revised  in  the  FEIS,  Chapter  1,   Interrelationships 
section 

94-4         The  text  has  been  revised  in  the  FEIS.  Chapter  2. 

94-5         The  total  miles  of  salmonid  habitat  are  indicated  in  the  DEIS, 

Chapter  3,  page  77.   it  can  also  be  determined  from  Chapter  2,  Table 
2-11,  by  adding  the  miles  of  8LM  habitat  for  resident  trout. 

94-6         See  response  to  comment  85-4. 

94-7         Refer  to  DEIS     Chapter  3,  page  79.  Also,   see  response  to  comment 
74-3. 


94-8         Refer  to  DEIS,  Appendix  C,  Table  C-4. 


149 


LIST  OF  AGENCIES,  ORGANIZATIONS  AND  PERSONS  TO  WHOM 
COPIES  OF  THE  STATEMENT  ARE  SENT 


Comments  on  the  draft  environmental  statement  were 
requested  from  the  following: 

Federal  Agencies 

Advisory  Council  on  Historic  Preservation 
Department  of  Agriculture 

Forest  Service 

Soil  Conservation  Service 
Department  of  Commerce 

National  Marine  Fisheries  Service 
Department  of  Defense 

U.S.  Army  Corps  of  Engineers 
Department  of  Energy 

Region  X 
Department  of  the  Interior 

Fish  and  Wildlife  Service 

Geological  Survey 

National  Park  Service 

Bureau  of  Mines 

Bureau  of  Reclamation 
Small  Business  Administration 
Environmental  Protection  Agency 

State  and  Local  Government 

Oregon  State  Clearinghouse 
Oregon  Regional  Clearinghouses 

Lane  Council  of  Governments 

Umpqua  Regional  Council  of  Governments 

Rogue  Valley  Council  of  Governments 
Oregon  State  Historic  Preservation  Officer 
Boards  of  County  Commissioners 

Douglas  County 

Copies  of  this  environmental  impact  statement  will  be 
available  for  public  inspection  at  the  following  BLM  offices: 


Interest  Groups  (partial  listing) 

American  Forest  Institute 

Associated  Oregon  Industries 

Association  of  O&C  Counties 

Cascade  Holistic  Economic  Consultants 

Friends  of  the  Earth 

Industrial  Forestry  Association 

Izaak  Walton  League 

Natural  Resource  Defense  Council 

National  Wildlife  Federation 

Northwest  Environmental  Defense  Center 

North  West  Timber  Association 

Oregon  Environmental  Council 

Oregon  Natural  Heritage  Program 

Oregon  Student  Public  Interest  Research  Group 

Oregon  Wilderness  Coalition 

Sierra  Club 

Southern  Oregon  Citizens  Against  Toxic  Sprays 

Southern  Oregon  Resource  Alliance 

Southern  Oregon  Timber  Industries  Association 

The  Wilderness  Society 

Western  Forest  Industries  Association 

Wildlife  Management  Institute 


Roseburg  District  Office 
777  NW  Garden  Valley  Blvd. 
Roseburg,  Oregon  97470 
Phone  (503)  672-4491 


Washington  Office  of  Public  Affairs 
18th  and  C  Streets 
Washington,  D.C.  20240 
Phone  (202)  343-5717 

Oregon  State  Public  Affairs  Office 
825  N.E.  Multnomah 
P.O.  Box  2965 
Portland,  Oregon  97208 
Phone  (503)  231-6277 

Reading  copies  will  be  placed  in  the  following  libraries:  Portland  State  University,  Portand;  Oregon  State  University, 
Corvallis;  University  of  Oregon,  Eugene;  Lane  Community  College,  Eugene;  and  Umpqua  Community  College, 
Roseburg;  and  public  libraries  in  Salem,  Canyonville,  Drain,  Glendale,  Myrtle  Creek,  Riddle,  Roseburg,  Winston  and 
Yoncalla. 


Copies  of  the  final  EIS  are  sent  to  each  person,  organization  or  agency  commenting  on  or  receiving  copies  of  the  draft 
document. 


150 


LIST  OF  PREPARERS 


While  individuals  have  primary  responsibility  for  preparing  sections  of  an  EIS,  the  document  is  an 
interdisciplinary  team  effort.  In  addition,  internal  review  of  the  document  occurs  throughout  preparation. 
Specialists  at  the  District  and  State  Office  levels  of  the  Bureau  both  review  the  analysis  and  supply 
information.  Contributions  by  individual  preparers  may  be  subject  to  revision  by  other  BLM  specialists  and 
by  management  during  the  internal  review  process. 


Name 

Dick  Bonn 


D.  F.  Buck,  Jr. 


L.  D.  Hamilton 


Primary  Responsibility 


Discipline 


Team  Leader,  Soils,  Human       Biologist 
Health 


Air,  Water,  Climate,  Geology       Soil  Scientist 


Technical  Coordinator/Editor       Geography 


Related  Professional 
Experience 

4-1/2  years  BLM  (Environmental 

Specialist)  Portland,  Oreg. 

11  years  SCS 

2-1/2  years  (Biologist)  Watershed 

&  River  basin,  Columbus,  Ohio. 

2-1/2  years  (Biologist)  Watersheds 

Richmond,  VA. 

4  years  (Biologist  &  Recreation) 
Albany,  Oreg. 

2  years  (Soil  Conservationist) 
Harrisburg,  Oreg. 

5  years  BLM  (Soil  Scientist, 
Environmental  Protection 


Specialist) 


11   years  (Outdoor  Recreation 
Planner,  Environmental  Protection 
Specialist)  moved  to  Colorado, 
March  1982. 


Phillip  D.  Havens       Fisheries  &  Wildlife 
Jeanne  Johnson         Editorial  Assistant 

R.  Michael  Martin      Socioeconomics 


Wildlife  Biology     18  years  (Wildlife  Biologist) 


Joseph  Ross 


Recreation,  Cultural 
Resources,  Wilderness,  Areas 
of  Critical  Environmental 
Concern,  Special  Areas, 
Visual  Resources  and  Energy. 


R.  Gregg  Simmons    Description  of  the  Proposed 
Action  and  Alternatives, 
Vegetation 


Administrative 
Secretary 

Economics 

Recreation 


Forest 
Management 


7  years  BLM  (Secretary,  Editorial 
Assistant 

6  years  (Economist) 

8  years  (Forestry  Technician, 
Biological  Information  Specialist, 
Outdoor  Recreation  Planner) 


8  years  BLM  (Forester) 
5  years  Eugene,  Oreg. 
3  years  Portland,  Oreg. 


151 


Roseburg  District  Personnel  Contributing  Substantial  Input 

Name  Primary  Responsibility  Discipline 


Related  Professional 
Experience 


Robert  L.  Alverts 


Stewart  H.  Avery 


Robert  W.  Bright 


Planning  coordination,  Forest 

information  supply,  document   Management 
review 


Information  supply,  document   Forest  Engineering 
review 


Information  supply,  document   Forest 
review  Management 


Bennie  C.  Hobbs        Information  supply,  document   Forest 

review  Management 


Dennis  E.  Hutchison   Soils,  Air,  Water  information, 
document  review 


Joseph  B.  Lint 


John  R.  Norlin 


Wildlife  information, 
document  review 


Forestry  information, 
document  review 


Resource 
Management  (Soil 
Science) 


Wildlife  Biology 


Forest 
Management 


Franklin  M.  Oliver       Fisheries  information, 
document  review 


David  R.  Palmer 


Robert  A.  Smith 


Forestry  information, 
document  review 


Fish  Biology 


Forest 
Management 


Information  supply,  document   Forest 
review  Management 


16  years  BLM  (Forester,  Area 
Manager,  Planning  & 
Environmental  Coordination) 

7  years  Medford 

4  years  Burns 

5  years  Roseburg 

25  years  BLM  (Forester,  District 
Engineer,  Resource  Manager, 
Area  Manager) 
5  years  Medford 

20  years  Roseburg 

21  years  BLM  (Forester,  Planning 
Coordinator,  Area  Manager) 

16  years  Roseburg 
5  years  Susanville 

13  years  BLM  (Forester,  Timber 
Manager,  Area  Manager) 

10  years  Eugene 

3  years  Roseburg 

14  years  (10  SCS,  4  BLM) 

8  years  Midwest  and  East 

2  years  Idaho 

4  years  Roseburg 

8  years  BLM  (Biologist) 
4  years  Coeur  'd  Alene 

4  years  Roseburg 

25  years  (5  BIA,  20  BLM)  Forester, 
Timber  Manager,  Realty  Spec, 
Timber  Management  Spec.) 

3  years  Midwest 

2  years  E.  Wash. 

5  years  Tillamook 

15  years  Roseburg 

18  years  (5  years  Oregon 
Department  of  Fish  &  Wildlife,  13 
years  BLM,  Fish  Biologist) 
18  years  Roseburg 

7  years  BLM  (Forester) 
7  years  Roseburg 

32  years  BLM  (Forest  and  Range 
Management,  Fire  Control, 
Area  Manager) 

14  years  Alaska 

3  years  Burns 

15  years  Roseburg 


153 


Appendices 


Page 

Appendix  A  —  O&C  Forest  Resources  Policy  to  be  Used  in  Developing  Plans 

for  BLM-administered  Forest  Lands  in  Western  Oregon 154 

Appendix  B  —  Results  of  Scoping 1 59 

Appendix  C  —  Development  of  the  Proposed  Action  and  Alternatives 1 65 

Appendix  D  —  Wildlife 1 73 

Appendix  E  —  Alteration  of  Wildlife  Habitat  on  BLM-administered 

Forest  Land 1 79 

Appendix  F  —  Predicted  Alteration  of  Wildlife  Habitat  on  All  Forest 

Lands  in  the  EIS  Area 1 84 


154 


Appendix  A 

O&C  Forest  Resources  Policy 
to  be  Used  in  Developing  Plans 
for  BLM  Administered  Forest 
Lands  in  Western  Oregon 

This  statement  sets  forth  BLM  policy  for 
management  of  the  Revested  Oregon  and 
California  (O&C)  Railroad  and  reconveyed  Coos 
Bay  Wagon  Road  Grant  lands  situated  in  the  State 
of  Oregon.  It  reflects  the  provisions  of  the  Act  of 
August  28,  1937  (O&C  Act),  and  the  effects  of 
other  relevant  legislation  and  Executive  Orders. 

The  BLM  manages  2.1  million  acres  of  O&C  lands 
in  western  Oregon.  The  revenues  and  employment 
generated  by  timber  sales,  conversion  of  timber  to 
wood  products,  and  other  marketable  values 
derived  from  these  lands  significantly  affect  the 
State  and  local  economies.  It  is  further  recognized 
that  public  use  of  these  lands  through 
consumptive  and  non-consumptive  recreation, 
including  sport  hunting  and  sport  and  commercial 
harvest  of  salmon  and  steelhead  produced  in 
streams  on  the  O&C  lands,  also  contributes  to  the 
local  and  State  economies.  The  primary  objectives 
of  the  management  program  on  the  O&C  lands  are 
to  manage  for  a  high-level  and  sustained  yield 
output  of  wood  products  needed  to  contribute  to 
the  economic  stability  of  the  local  communities 
and  industries,  and  to  provide  for  other  land  uses 
as  established  in  the  O&C  Act  and  other 
legislation. 

The  following  principles  will  guide  BLM  in 
managing  the  forest  resources  on  O&C  lands: 

1.  Resource  management  plans  or  management 
framework  plans  as  developed  through  the  land- 
use  planning  process  shall  constitute  the  primary 
guides  for  carrying  out  legislative  mandates  and 
Bureau  policies. 

2.  All  O&C  land  administered  by  BLM  in  western 
Oregon  will  be  classified  according  to  the  Timber 
Production  Capability  Classification.  Lands 
classified  as  suitable  for  timber  production  shall 
be  managed  for  timber  and  wood  product 
production,  to  the  extent  possible,  under  the 
requirements  of  law.  Lands  classified  as 
nonsuitable  for  timber  producton  shall  be 
allocated  to  the  fullest  extent  possible  to  meet  the 
needs  for  non-timber  public  land  uses.  Where 
nonsuitable  lands  cannot  adequately  provide  for 
other  uses  set  forth  in  the  O&C  Act  and  other 
applicable  legislation  and  Executive  Orders, 
suitable  lands  may  be  managed  to  meet  the  needs 
for  the  following: 

a.  Maintenance  of  water  quality  in  accordance 
with  Federal  and  State  standards.  Timber 
harvesting  may  be  restricted  or  excluded  only  in 


areas  where  mitigating  measures  will  not  maintain 
water  quality  standards. 

b.  Protection  of  wetlands,  including  riparian 
zones.  Timber  harvesting  may  be  restricted  or 
excluded  only  in  areas  where  mitigating  measures 
will  not  be  effective. 

c.  Conservation  of  specifically  identified  habitats 
for  federally  listed,  threatened  and  endangered 
species.  Timber  harvesting  may  be  restricted  or 
excluded  only  in  areas  where  mitigating  measures 
will  not  be  effective. 

d.  Research  and  development  pertinent  to  the 
management  of  the  land  resources.  Timber 
harvesting  may  be  restricted  or  excluded  only  in 
areas  where  mitigating  measures  will  not  maintain 
resource  values,  and  research  is  assessing  these 
values:  timber  harvesting  may  be  restricted  or 
excluded  pending  the  research  conclusions. 

e.  Consideration  of  State  goals  and  objectives 
concerning  State-listed,  threatened  and 
endangered  species  in  land-use  planning  and 
management.  Restrictions  may  be  utilized  to 
achieve  the  habitat  objectives  developed  from  the 
BLM  plans. 

f.  Consideration  of  habitat  needs  of  native  species. 
Restriction  of  timber  harvest  may  be  considered 
when  these  habitat  needs  cannot  be  met  through 
established  timber  harvest  practices. 

g.  Protection  of  developed  high-value  recreation 
areas,  including  the  visual  quality  of  significant 
scenic  areas.  Restriction  or  exclusion  of  timber 
harvest  may  be  considered  in  the  protection  of 
established  recreation  facilities.  Timber  harvest 
may  be  restricted  in  the  protection  of  scenic  areas 
only  where  mitigating  measures  will  not  prove 
effective. 

3.  The  allowable  cut  determination  shall  be  based 
on  a  nondeclining  harvest  level  over  time. 
Departures  from  the  nondeclining  harvest  level 
may  be  permitted  in  either  direction.  Any 
increases  shall  not  exceed  the  long-term 
sustained  yield  capacity  of  the  land;  decreases 
shall  be  economically  and/or  biologically  justified 
and  timed  so  as  to  minimize  impacts  on 
dependent  industries  and  local  economies. 

The  Serai  Stage 
Distribution  Concept 

The  mid-age  and  old  growth  stands  remaining 
today  are  the  result  of  complex  interactions 
between  plants  and  animals  over  time.  Evidence 
points  towards  the  simultaneous  evolution  of 
these  plants  and  animals.  Yet,  the  exact 
functioning  and  purpose  of  many  of  these 
interactions  have  not  yet  been  studied  in  depth. 
For  example,  the  mechanisms  for  nitrogen  fixation 
have  only  been  identified  within  the  past  decade. 


155 


Additionally,  there  are  indications  that  mycorrhizal 
inoculation  by  rodents  may  be  critical  to 
plantation  establishment  and  survival  in  some 
instances  (Franklin  et  al.  1981).  There  are  many 
unknowns  regarding  which  portions  of  this 
interacting  web,  if  any,  must  be  replicated  by 
management  if  long-term  timber  production  is  to 
be  maintained  at  high  levels.  What  is  known, 
however,  is  that  the  timber  management  program 
would  liquidate  the  remaining  old  growth  stands 
in  a  relatively  short  time  if  unconstrained. 

Seed  zones  are  accepted  as  generally 
encompassing  a  geographic  area  within  which  the 
factors  affecting  reforestation  and  subsequent 
growth  are  relatively  homogenous.  Mid-age  and 
old-growth  timber  in  areas  allocated  to  long-term 
timber  productivity;  habitat  for  old  growth  related 
species,  including  the  northern  spotted  owl; 
riparian  habitat;  and  high  scenic  quality  provides 
adequate  coverage  of  seed  zones  in  the  Roseburg 
District  (see  Appendix  C,  Modified  Area  Control). 

For  all  districts  in  western  Oregon  most  seed 
zones  where  old  growth  currently  exists  are 
adequately  covered.  Table  A-1  and  Figure  A-1 
indicate  the  seed  zones  which  cover  the  five 
western  Oregon  district  boundaries. 


Table  A-1  Tree  Seed  Zones  by 
Elevation  in  Western  Oregon 


Zone 

Elevation 

District 

053 

1,500 

-  2,000 

Salem 

061 

1,000 

-  1,500 

Salem 

061 

1.500 

-  2,000 

Salem 

061 

2,000 

-2,500 

Salem 

062 

500 

-  1,000 

Coos  Bay 

062 

500 

-  1 .000 

Coos  Bay 

062 

1,000 

-  1,500 

Eugene 

062 

1,000 

-  1,500 

Coos  Bay 

062 

1,500 

-  2,000 

Coos  Bay 

071 

500 

-  1 .000 

Coos  Bay 

071 

500 

-  1,000 

Coos  Bay 

071 

1,000 

-  1,500 

Coos  Bay 

071 

1,000 

-  1.500 

Coos  Bay 

071 

1,500 

-  2,000 

Coos  Bay 

071 

1,500 

-  2,000 

Coos  Bay 

071 

2,000 

-  2,500 

Coos  Bay 

072 

500 

-  1,000 

Coos  Bay 

072 

500 

-  1,000 

Coos  Bay 

072 

1,000 

-  1,500 

Coos  Bay 

072 

1,000 

-  1,500 

Coos  Bay 

072 

1.500 

-  2,000 

Coos  Bay 

072 

1.500 

-  2,000 

Coos  Bay 

072 

2,000 

-  2,500 

Coos  Bay 

072 

2,000 

-  2,500 

Coos  Bay 

072 

2,500 

-  3,000 

Coos  Bay 

072 

2,500 

-  3,000 

Coos  Bay 

251 

1,500 

-  2,000 

Salem 

252 

500 

-  1.000 

Coos  Bay 

252 

500  ■ 

-  1,000 

Roseburg 

252 

500  ■ 

-  1,000 

Eugene 

252 

1.000 

-  1,500 

Eugene 

252 

1.000 

-  1,500 

Eugene 

252 

1,000- 

-  1,500 

Roseburg 

252 

1.500- 

•  2,000 

Salem 

270 

500  - 

■  1 ,000 

Roseburg 

270 

1,000  - 

1,500 

Roseburg 

270 

1,000  - 

■  1,500 

Roseburg 

270 

1,500  - 

■  2,000 

Roseburg 

270 

2,000- 

2.500 

Roseburg 

270 

2,500- 

■  3,000 

Medford 

452 

1,500  - 

2,000 

Salem 

452 

3,000  - 

■3.500 

Salem 

452 

3,500  - 

■4,000 

Salem 

461 

1,000- 

1,500 

Salem 

461 

1.500- 

•  2,000 

Salem 

461 

2,000  - 

■2,500 

Salem 

461 

2,500  - 

3,000 

Salem 

461 

3.000  - 

3,500 

Salem 

461 

3.500- 

4,000 

Salem 

462 

1,500- 

2,000 

Salem 

481 

1.500  - 

2.000 

Eugene 

481 

2,000  - 

2,500 

Eugene 

481 

2,500- 

3,000 

Eugene 

491 

500- 

1,000 

Roseburg 

491 

1,000- 

1,500 

Roseburg 

491 

1,500- 

2,000 

Roseburg 

491 

2.000- 

2,500 

Roseburg 

491 

2.500- 

3,000 

Roseburg 

491 

3,000  - 

3,500 

Roseburg 

491 

3,500  - 

4,000 

Roseburg 

492 

1.000  - 

1,500 

Roseburg 

492 

1.500- 

2,000 

Roseburg 

492 

2.000- 

2,500 

Roseburg 

492 

2,500- 

3,000 

Roseburg 

492 

3,000  - 

3,500 

Roseburg 

492 

3.500- 

4,000 

Medford 

051 


053 

S 


U    S    DEPARTMENT  OF  THE  INTERIOR 

S*\ 

BUREAU  OF  LAND  MANAGEMENT 

052 

R        J 

) 
( 

061 


042 


451 


'252 


262 


471 


k 

452 

M 

461 

462 

[463 

L 

052 


472 


071 

North  Bend 
Coos   Boy 


I 


072 


CO 
O 

081 

o 


082 
090 


®< 


© 


482 


481 


491 

R  10    S     E     B     U      R 

!)  Roseburg 

492 


512 


FIGURE    A-1 
WESTERN  OREGON   TREE   SEED   ZONES 


501 


502 


D 


0 


511 


701   D 


721 


Scale   1:1,000.000 


261       Seed  Zones  Numbers 
^^      Seed  Zones  Boundary 


159 


Appendix  B 
Results  of  Scoping 
Scoping  Meeting 

On  October  19,  1981,  as  part  of  BLM's  land 
use  planning  process,  a  public  meeting  was  held 
at  the  Roseburg  District  Office  to  discuss 
important  issues  and  alternatives  that  should  be 
addressed  in  the  Environmental  Impact  Statement 
(EIS)  for  the  Douglas-South  Umpqua  Timber 
Management  Plan. 

Participants  in  the  meeting  suggested  19  different 
alternatives  for  consideration  in  the  EIS.  The 
alternatives  suggested,  and  BLM's  analysis  of  their 
usefulness  and  relevance  to  the  EIS  process,  are 
summarized  as  follows: 

1.  Maximum  Timber  Production.  This  alternative 
would  modify  land  use  Alternative  "A"  as 
described  in  the  Preferred  Land  Use  Alternative 
Summary  brochure,  by  providing  full  timber 
harvest  in  riparian  areas  and  reducing  visual 
buffers  around  recreation  areas.  It  established  one 
end  of  a  range  of  alternatives  for  analysis  in  the 
EIS. 

2.  Maximum  Timber  Production  Without 
Economic  Constraints.  This  alternative  would 
modify  Alternative  1  by  including  all  intensive 
timber  management  practices  that  are  technically 
feasible,  whether  or  not  they  were  cost  effective. 
Upon  analysis,  BLM  concluded  that  all  technically 
feasible  practices  were  cost  effective  and  thus 
were  automatically  included  in  Alternative  1. 

3.  Preferred  Alternative  Without  Old  Growth 
Habitat.  This  would  vary  from  the  Preferred  by 
including  the  old-growth  habitat  (spotted  owl 
areas,  old  growth  blocks  and  80-acre  blocks)  in 
the  intensive  timber  management  base.  This 
defines  an  analytically  useful  and  relevant  land 
use  allocation  alternative  between  Alternative  1 
and  the  preferred  alternative. 

4.  Preferred  Alternative  but  Include  Spotted  Owl 
Areas  in  Allowable  Cut  Computation.  This 
alternative  would  not  permit,  during  the  plan 
period  (decade),  cutting  of  the  spotted  owl  areas 
protected  in  the  Preferred;  but  the  allowable  cut 
would  be  calculated  as  if  that  land  were  available 
for  timber  harvest.  This  would  offer  little  analytical 
utility  as  it  would  simply  propose  a  somewhat 
faster  rate  of  timber  harvest  on  the  preferred  land 
base,  varying  all  impacts  that  are  strictly 
dependent  on  the  rate  of  cutting  (e.g.,  economic 
benefits,  erosion  and  sediment  yield). 

5.  Review  Wildlife  Mitigating  Measures.  The  thrust 
of  this  alternative  was  to  obtain  a  higher  timber 
harvest  than  the  preferred  alternative  by  addition 
of  measures  to  mitigate  impacts  on  wildlife  with 
less  reductions  in  potential  timber  harvest. 
Analysis  after  the  meeting  led  to  the  conclusion 


that  the  preferred  alternative  included  all  feasible 
measures  that  would  achieve  higher  timber 
harvest  and  meet  the  wildlife  goals. 

6.  Strong  Emphasis  on  Protection  of  Natural  and 
Cultural  Resources.  This  would  be  similar  to 
Alternative  "D"  in  the  Preferred  Land  Use 
Alternative  Summary  Brochure,  but  modified  to 
exclude  intensive  forest  management  practices 
which  enhance  timber  yield.  This  includes 
protection  of  a  variety  of  wildlife  habitats,  sensitive 
botanical  species,  cultural  resources,  visual 
resources,  research  natural  areas,  riparian  areas 
and  undeveloped  recreation  activities  and 
facilities. 

Approximately  263, 7001  acres  of  commercial 
forest  land  would  be  managed  on  a  60-year 
minimum  harvest  age,  although  no  intensive 
management  practices  which  enhance  timber 
yield  would  be  applied  to  harvested  areas  after 
planting.  Fifteen  year  spacing  between  harvest 
areas  would  be  employed.  An  additional  127,400 
acres  of  commercial  forest  land  would  be 
withdrawn  from  the  allowable  cut  base  to  protect 
the  resources  listed  above.  Harvest  from  these 
areas  would  be  allowed  only  when  directly 
benefitting  the  protected  resources. 

7.  Full  Ecosystem.  This  alternative  is  intended  to 
emphasize  the  allocation  of  land  for  protection  of 
wildlife  habitat  diversity  and  related  values. 
Alternative  6  encompasses  this  approach. 

8.  Maintain  Old-Growth  Dependent  Species  and 
Non-Declining  Yield  of  Resources  Other  Than 
Timber.  Alternative  6  basically  would  achieve  this 
objective. 

9.  Limit  Timber  Management  to  Existing 
Developed  Land  to  Maintain  Wildlife  Habitat  and 
Watershed  Protection.  Alternative  6  would  also 
basically  achieve  this  objective. 

10.  No  Timber  Harvest.  This  alternative  would  not 
in  any  way  meet  the  primary  objective  of  the 
timber  management  plan—providing  a  sustained 
timber  harvest.  In  addition,  this  alternative 
received  only  limited  support  at  the  public 
meeting. 

11.  The  Natural  Situation  Before  BLM  Land 
Management  Began.  This  is  not  a  realistic 
alternative  as  no  BLM  management  could 
reestablish  this  situation.  In  addition,  this 
alternative  received  only  limited  support  at  the 
public  meeting. 

12.  Departure  From  Even  Flow.  This  suggestion 
assumed  that  first-decade  departure  from  even- 
flow  would  not  cause  a  subsequent  decline  below 
the  even-flow  level,  for  either  the  preferred  land 
base  or  the  land  base  in  Alternative  1 .  BLM 
analysis  has  shown,  however,  that  it  is  not 
possible  to  depart  from  even-flow  in  the  first 

1  Refinement  since  the  scoping  meeting  has  resulted  in  the  following 
breakdown  for  the  constrained  timber  production  base: 


160 


decade  without  causing  a  subsequent  decline 
below  the  even-flow  level.  Thus,  the  alternative  is 
not  viable. 

VRM  (MHA-130)  49,376 

Wildlife  (MHA-  60)  107,180 

Wildlife  (MHA -250)  83,211 

Wildlife  (MHA -350)  22,669 

13.  Lower  Average  Minimum  Harvest  Size.  This 
alternative  is  identical  to  the  preferred  alternative 
except  that  minimum  harvest  size  and 
corresponding  minimum  harvest  age  would  be 
reduced.  The  minimum  average  tree  diameter  in 
stands  selected  for  final  harvest  would  be  1 1 
inches  diameter  breast  height  (dbh)  compared  to 
14  inches  dbh  under  the  preferred  alternative.  The 
equivalent  minimum  harvest  age  would  be  40 
years  instead  of  50  years  as  in  the  preferred 
alternative.  This  alternative  is  considered  to  be 
analytically  useful  to  the  decisionmaker. 

14.  A  Constant  Budget.  This  alternative  would  be 
expected  to  show  whether,  in  the  long  run,  a 
constant  budget  would  support  the  increasing  use 
of  intensive  management  practices  planned  in  the 
Preferred  Alternative.  For  the  other  alternatives,  a 
constant  budget  is  assumed  for  the  short  term  (10 
year),  but  analysis  of  the  long-run  implications 
would  require  making  economic  assumptions 
extended  over  a  time  span  of  at  least  60  years  (the 
time  by  which  old  growth  on  lands  in  intensive 
management  would  be  harvested).  Such  long-term 
economic  forecasts  would  be  too  conjectural  to  be 
useful  to  the  decisionmaker;  however,  a  constant 
dollar  long-term  budget  will  be  displayed  for  the 
preferred  alternative. 

15.  Use  of  Different  Computer  Model  for  Allowable 
Cut  Computation.  This  is  a  relevant  suggestion 
which  will  be  investigated  for  application  to  the 
next  cycle  of  allowable  cut  determinations,  which 
will  begin  in  several  years.  At  this  stage  of  the 
current  process  it  is  not  practical  for  BLM  to 
obtain  a  different  computer  program  for  allowable 
cut  computations. 

16.  Economic  Optimum  for  Timber  Management. 
This  suggestion  focused  on  management  like  that 
of  an  industrial  forest,  with  a  goal  of  at  least  7 
percent  real  return  on  investment.  The  Bureau's 
planning  process  is  not  oriented  to  defining  such 
an  alternative,  but  the  revenues  and  costs  of 
timber  management  for  the  preferred  alternative 
will  be  defined  in  the  EIS. 

17.  Departure  from  Even-Flow  on  the  Preferred 
Land  Base,  with  a  Constant  Budget.  This  would 
combine  Alternatives  12  and  14,  which  as 
previously  stated,  are  not  viable  or  practical. 

18.  No  Fertilization,  No  Herbicides,  No  Credit  for 
Genetically  Improved  Trees.  This  alternative 
would  exclude  the  use  of  both  fertilizer  and 
herbicides  for  timber  management.  It  would 
provide  for  continued  planting  of  genetically 


improved  trees,  but  the  allowable  cut  computation 
would  not  take  credit  for  expected  growth 
increases.  It  is  a  relevant  and  useful  alternative  to 
analyze. 

19.  No  Fertilization,  No  Credit  for  Genetically 
Improved  Trees.  This  alternative  would  differ  from 
Alternative  18  only  in  one  dimension.  It  would  not 
be  analytically  useful  to  include  it  in  addition  to 
No.  18. 

The  above  analysis  concludes  that  five  alternatives 
suggested  at  the  meeting  were  relevant  and  useful 
to  analyze  in  addition  to  the  preferred  alternative 
and  the  No  Action  (continue  existing 
management)  Alternative.  These  seven 
alternatives  display  five  land  use  bases;  however, 
only  one  (Alternative  6)  represents  a  land  use 
allocation  with  an  allowable  cut  level  lower  than 
the  preferred  alternative.  For  comparative 
purposes,  another  land  use  allocation  alternative, 
with  an  allowable  cut  level  below  the  preferred 
alternative,  should  be  included.  Alternative  C, 
described  in  the  Preferred  Land  Use  Alternative 
Summary  Brochure,  fills  this  need. 

The  preceding  summary,  although  organized 
differently,  was  discussed  with  the  Roseburg 
District  Multiple  Use  Advisory  Council  on  October 

20,  1981.  The  Council  concurred  with  BLM's 
review  of  the  alternatives  and  the  recommended 
number  for  analysis  in  the  EIS.  There  was  a 
suggestion  to  include  an  additional  alternative  that 
would  allocate  only  the  best  timber  producing 
lands  to  intensive  timber  management,  leaving  the 
remainder  to  provide  benefits  for  wildlife,  water 
quality,  visual  quality  and  other  resources.  This 
approach,  although  not  supported  by  the  majority 
of  the  Council,  was  later  analyzed  by  BLM.  In  the 
development  of  the  preferred  alternative,  this 
approach  had  already  been  adopted  to  the  extent 
possible.  Its  utility  for  meeting  wildlife  and  related 
objectives  is  quite  limited,  however,  as  the  most 
productive  timber  land  also  has  the  highest 
productivity  for  certain  wildlife  species. 

Based  on  the  public  comments,  BLM  analysis  and 
District  Advisory  Council  recommendations,  we 
have  concluded  the  EIS  should  analyze  the 
following  alternatives: 

1.  Maximum  Timber  Production  (Discussion  Item 

1) 

2.  Emphasis  On  Timber  Production  (Discussion 
Item  3) 

3.  Lower  Minimum  Harvest  Size  (Discussion  Item 
13) 

4.  Proposed  Action 

5.  No  Action 

6.  Minimum  Necessary  Habitat  Diversity 
(Alternative  C  in  Summary  Brochure) 

7.  No  Herbicides,  Fertilizer  or  Allowable  Cut  Effect 
for  Genetics  (Discussion  Item  18) 

8.  Emphasis  on  Protection  of  Natural  and  Cultural 
Resources  (Discussion  Item  6) 


161 


The  public,  through  the  EIS  scoping,  did  an 
excellent  job  of  defining  a  number  of  issues  they 
believed  the  EIS  should  address. 

Analysis  showed  that  most  of  the  issues  fell  within 
the  broad  range  of  issues  listed  in  the  handout 
used  to  begin  the  discussion  at  the  EIS  scoping 
meeting.  Following  is  a  revised  list  of  issues  to  be 
discussed  in  the  EIS.  These  are  environmental 
values  which  could  be  significantly  impacted  by 
the  timber  management  proposal  or  other 
alternatives  as  seen  by  the  public: 

Air  Quality  -  smoke  management 

Soils  -  fragile  areas;  erosion  potential 

Water  -  quality  and  quantity;  impacts  from 
intensive  management  practices;  municipal 
watersheds;  rural  and  domestic  watersheds; 
impact  of  adjoining  landowners. 

Vegetation  -  threatened  and  endangered  species, 
consistency  with  Endangered  Species  Act; 
riparian,  consequences  of  different  protection 
levels;  old  growth,  amount  and  distribution; 
consequences  of  herbicide  use  compared  with 
other  vegetation  management  alternatives. 

Fish  and  Wildlife  -  threatened  and  endangered 
species,  consistency  with  Endangered  Species 
Act;  habitat  diversity,  impacts  of  intensive 
management  practices,  difficulties/opportunities 
in  mixed  land  pattern,  consequences  of  different 
minimum  harvest  ages;  nongame  species,  species 
list,  abundance,  distribution,  snag  retention  policy 
by  alternative;  big  game  species  and  anadromous 
fish,  impacts  of  roads,  impacts  of  cover  removal, 
impacts  of  intensive  management  practices; 
northern  spotted  owls,  decadal  population  levels, 
possible  listing  as  threatened/endangered  species, 
impacts  of  intensive  management  practices; 
schedule  of  mitigating  or  enhancing  practices; 
consideration  of  non-suitable  timberland  for 
allocation  to  wildlife;  corridors,  objectives, 
benefits,  consequences. 

Social  Conditions  -  consideration  of  adjoining 
landowners. 

Economic  Conditions  -  public  revenue;  personal 
income;  employment;  dependent  communities; 
funding  mechanisms;  benefit/cost  relationships; 
opportunity  costs  of  management  strategies. 

Recreation  -  economic  basis  for  recreation 
opportunity,  including  hunting  and  fishing. 

Visual  Resources  -  difficulties/opportunities  in 
mixed  land  pattern;  consideration  of  adjoining 
landowners. 

Cultural  Resources  -  protection  of  sites 

Human  Health  -  impacts  of  herbicides 

Areas  of  Critical  Environmental  Concern  (ACECs) 


Intensive  Forest  Management  Practices  -  genetic 
tree  improvement;  use  of  different  silvicultural 
systems;  consideration  of  non-suitable  forestland 
for  other  uses;  volume  contribution  of  intensive 
practices;  limitations  on  size  and  timing  of 
clearcuts;  description  of  current  intensive 
practices  and  proposed  practices;  description  of 
allowable  cut  calculations;  display  of  yield 
equations. 

Several  topics  were  surfaced  as  issues  for 
discussion.  Although  monitoring  was  suggested 
as  an  issue,  it  is  not  practical  to  develop  a  realistic 
monitoring  plan  for  each  alternative  in  the  EIS.  A 
full  monitoring  plan  will  be  developed  and 
included  as  an  appendix  to  the  decision  document 
to  be  prepared  after  completion  of  the  EIS. 

Some  additional  aspects  of  economic  analysis 
were  suggested.  It  is  felt  that  the  topic  list  under 
economics  is  a  broad  framework  and  other  items 
suggested  as  economic  issues  are  encompassed 
within  this  framework. 

Near  the  end  of  the  meeting,  the  audience  was 
asked  for  its  preference  on  meetings  which  could 
be  held  during  the  public  comment  period  on  the 
draft  EIS.  An  unstructured  public  meeting  and/or 
a  formal  hearing  were  offered  for  discussion.  The 
response  favored  both  kinds  of  sessions,  although 
opinions  were  mixed  on  the  issue.  A  portion  of  the 
group  preferred  no  meetings  at  all,  remarking  that 
written  comments  should  be  more  than  adequate. 

Scoping  Correspondence 

Subsequent  to  the  discussion  of  alternatives 
with  the  Roseburg  District  Multiple  Use  Advisory 
Council,  two  letters  were  received.  One  letter 
suggested  an  alternative  which  assumes  the 
average  management  intensity  and  departs  above 
the  long-run  sustained  yield  (LRSY).  Although  the 
LRSY  would  be  substantially  lower  than  for  other 
alternatives,  there  would  be  surplus  old  growth 
volume  permitting  harvest  above  LRSY.  Under  the 
intensity  of  management  in  the  preferred 
alternative  there  would  be  no  available  surplus 
volume.  Surplus  volume  may  be  created  by  using 
the  above  suggested  assumptions  which  constrain 
the  sustainable  harvest  level.  Including  an 
alternative  in  the  EIS  to  "create"  surplus  inventory 
in  such  a  way  was  not  considered  useful  enough 
analytically,  or  to  the  decisionmaker,  to  warrant 
the  resultant  increased  complexity  of  the  EIS. 

The  other  letter  proposed  a  departure  alternative 
that  would  increase  the  annual  sale  program  in  the 
first  two  or  three  decades  after  which  the  harvest 
level  would  be  allowed  to  drop  by  no  more  than  5 
percent  below  the  even-flow  level.  It  suggested 
that  this  analysis  be  applied  to  the  maximum 
timber  land  base  (Alternative  1),  the  maximum 
timber  base  with  provisions  for  spotted  owls 
(Alternative  2)  and  the  preferred  alternative  land 
use  allocation  (Alternative  4). 


162 


Although  it  is  interesting  to  analyze  the  effects  of 
these  three  alternatives  on  harvest  levels, 
inclusion  of  them  as  full  alternatives  in  the  EIS 
would  make  the  EIS  very  cumbersome  and  add 
little  dimension  to  the  analysis  of  impacts  other 
than  socioeconomic  impacts.  Accordingly,  they 
are  not  included  in  the  EIS,  but  the  resultant 
harvest  levels  have  been  computed.  The  annual 
timber  sale  programs  (using  a  two  decade 
increase  with  a  5  percent  decline  below  the 
evenflow  level  in  succeeding  decades)  are  shown 
below  in  million  board  feet: 


Decade 


Alt.  1 


Alt.  2 


Alt.  4 


1 

329 

303 

283 

2 

329 

303 

283 

3+ 

274 

254 

237 

Economic  Efficiency  Discussion 

During  the  EIS  scoping  process  four  economic 
analyses  were  requested  by  members  of  the 
public.  The  DEIS  presented  four  different  looks  at 
the  Original  Proposed  Action  (Alt.  4)  from  an 
economic  perspective.  In  response  to  comments 
received,  these  analyses  are  expanded  where 
clarity  was  lacking  in  the  DEIS  and  abbreviated 
where  a  summary  of  findings  would  suffice.  The 
substantive  change  is  to  supplement  projections 
of  growth  rates  in  the  value  of  timber  adjusted  for 
inflation  with  two  baseline  price  levels.  The 
average  sales  value  of  timber  on  the  Roseburg 
District  in  Fiscal  Year  1981  (FY  81)  was  $260  per  M 
bd.  ft.  The  average  value  for  fiscal  year  1982  was 
$94  per  M  bd.  ft. 

Economic  Efficiency  of  the  Timber  Management 
Program  in  the  New  Preferred  Alternative  (Alt.  9). 

The  timber  management  programs  in  both  the 
Original  Proposed  Action  and  the  Preferred 
Alternative  would  yield  $6.72  in  timber  sale 
receipts  for  every  dollar  of  costs  at  the  FY  81  sales 
value  of  $260  per  M  bd.  ft.  Each  program  would 
yield  $2.43  in  timber  sale  receipts  for  each  dollar 
spent  at  the  FY  82  sales  value  of  $94  per  M  bd.  ft. 
Table  B-1  identifies  for  Alternatives  4  and  9  the 
annualized  costs  of  major  program  elements  for 
fiscal  years  1984-93.  The  district's  proposed 
budget  for  FY  83  is  displayed  for  reference. 
Recognize  two  important  facts  when  comparing 
budgets  in  the  alternatives  with  dollars 
programmed  for  FY  83.  Since  BLM  has  accepted 
responsibility  for  prescribed  burning  on  the 
district  lands,  fire  management  costs  will  increase 
substantially  (with  any  alternative)  in  the  new  plan 
over  the  amount  budgeted  for  FY  83.  Similarly, 
timber  management  costs  rise  beginning  in  FY  84 
even  if  programmed  output  is  held  constant 
(Alternative  5).  This  reflects  the  fact  that  the 
district  in  1984  would  have  a  larger  percentage  of 
its  land  base  receiving  more  levels  of  management 
than  it  did  in  1972.  Determining  allowable  cut 
levels  decade  by  decade  causes  discrete  jumps  in 


management  requirements  to  occur  with  each  new 
allowable  cut  declaration.  If  the  FY  83  budget  is 
maintained  for  the  decade,  the  sustainable  output 
is  estimated  to  be  184  MM  bd.  ft.  per  year. 

Economic  Efficiency  of  the  Forest  Management 
Practices  in  the  New  Preferred  Alternative  (Alt.  9). 

Commercial  forest  land  in  the  Roseburg  District  is 
managed  under  the  principle  of  sustained  yield. 
The  thrust  of  the  district's  forestry  program  is  to 
achieve  economic  and  silvicultural  efficiency  and 
environmental  protection  consistent  with  a  high 
level  of  annual  or  regular  periodic  output  of 
timber.  The  district  has  developed  a  forestry 
program  for  its  Management  Framework  Plan 
(MFP).  Among  other  goals,  the  selected  forestry 
program  targets  a  package  of  management 
practices  which,  ultimately,  would  be  applied  to 
most  acres  on  the  district's  commercial  forest 
land.  Practices  chosen  by  the  district  include  tree 
improvement  through  genetic  selection,  spacing 
management  (precommercial  and  commercial 
thinning)  and  fertilization.  This  was  the  set  of 
practices  which  the  district  found  to  be  technically 
and  environmentally  feasible.  This  section 
contrasts  the  economic  payoff  of  the  complement 
of  practices  adopted  in  the  Preferred  Alternative 
with  other  possible  management  combinations. 

Research  has  established  that,  at  the  margin,  each 
of  these  practices  yields  a  favorable  ratio  of 
discounted  dollar  benefits  to  discounted  dollar 
costs  when  applied  to  forests  which  are  managed 
under  sustained  yield  and  have  an  abundance  of 
mature  timber  (allowable  cut  effect;  see  Beuter 
and  Handy  1974  and  Hoyer  1975).  Increasingly,  as 
the  ratio  of  mature  to  immature  timber  declines, 

Table  B-1  Cost  of  Forest  Management 
in  the  New  Preferred  Alternative 
(Alt.  9)  and  Original  Proposed  Action 
(Alt.  4). 


Major  Program  Area 
Affecting  Timber  Harvest, 
Reforestation  and  Growth 

Transportation  Systems' 
Timber  Management 
Fire  Management2 
Wildlife 
Soil/Air/Water 

Total 


Annual  Cost  in 
Thousands  of  Dollars 


Alt.  4 

Alt.  9 

FY  1983 

OPA 

NPA 

$1,696.6 

$1,683.0 

$1,134.9 

7,174.8 

7,120.9 

5,176.7 

529.4 

525.1 

183.3 

128.0 

128.0 

110.0 

100.0 

100.0 

94.0 

$9,628.8   $9,557.0   $6,698.9 


1  This  category  does  not  include  funding  for  bridges,  road  and 
aggregate  production  projects  handled  through  the  Federal 
Highway  Administration  Funding  for  these  projects  is  held  at  the 
State  Office.  An  estimated  $500,000  is  needed  for  these  con- 
struction projects. 

2  Program  areas  directly  related  to  reforestation  and  growth. 


the  significance  of  an  allowable  cut  effect 
dwindles.  The  district's  target  is  a  package  of 
practices  which  is  economically  efficient  both  now 
and  in  future  decades  where  there  is  no  allowable 
cut  effect  (as  early  as  the  fifth  decade  under  the 
Alternatives  1  through  5  and  9).  The  district 
analyzed  packages  of  practices  by  soil 
expectation  value  per  acre,  where  soil  expectation 
value  is  defined  to  be  the  value  today  of  initiating 
a  management  program  on  a  nonstocked  acre  and 
maintaining  that  program  throughout  the  future. 
Soil  expectation  values  net  discounted  dollar 
costs  from  discounted  dollar  returns.  For 
comparability,  each  complement  of  practices  is 
applied  to  average  site  conditions  on  the 
Roseburg  District  (the  Bureau's  allowable  cut 
modeling  is  based  on  the  average  site  conditions 
in  each  sustained  yield  unit).  Soil  expectation 
values  are  ranked  using  discount  factors  net  of 
inflation  of  4  percent,  7.625  percent  and  10 
percent  per  year.  The  4  percent  rate  is  the  factor 
by  which  the  U.S.  Forest  Service  discounts  future 
returns  and  costs  of  forest  management  to 
determine  an  equivalent  value  in  today's  dollars. 
Their  analysts  argue  that  a  4  percent  return  net  of 
inflation  is  comparable  to  the  yield  on  new  long- 
term  investments  in  the  private  sector  (Row  et  al. 
1981).  They  also  argue  that  the  value  of  timber  will 
appreciate  1.65  percent  per  year  faster  than 
general  inflation  for  50  years  (Haynes  et  al.  1980). 

Table  B-2  summarizes  the  district's  findings. 
Arrayed  are  packages  of  practices  which 
maximize  soil  expectation  value  at  various 
discount  rates  and  possible  levels  of  price 
appreciation. 

Table  B-2  Package  of  Practices 
Which  Maximizes  the  Soil  Expectation 
Value  of  Roseburg  District  Acres 
Reforested  1984-1993  at  Various 
Discount  Rates  and  Levels  of  Price 
Appreciation 


163 

Budget  and  Revenue  Implications  of  the  New 
Preferred  Alternative  (Alt.  9). 

When  measured  in  constant  dollars,  the 
budget  requirements  of  the  Preferred  Alternative 
increase  through  the  first  four  decades  and  then 
steadily  decline  in  the  fifth  through  14th  decades 
(Table  B-3).  The  trend  in  revenues  is  tied  to  both 
the  long-term  changes  in  the  value  of  timber  and 
the  type  of  timber  BLM  will  offer  in  the  future. 
Today,  in  second-growth  management,  log  values 
and  logging  costs  are  sensitive  to  the  average 
diameter  and  volume  harvested  per  acre  (Sessions 
1979).  Each  of  the  alternatives  yields  a  diameter 
size  class  to  harvest  acres  to  decade  relationship. 
Table  B-3  reports  prospective  revenues  by  decade 
for  three  possible  combinations  of  base  price  and 
appreciation  in  the  value  of  timber  (adjusted  for 
inflation).  The  table  addresses  questions  raised  by 
members  of  the  public  in  the  EIS  scoping  process. 
Some  participants  felt  that  the  costs  of  the  timber 
management  program  in  future  decades  may  well 
exceed  revenues.  The  column  in  Table  B-3  labeled 
net  return  indicates  that  total  revenues  of  the 
Preferred  Alternative  will  exceed  total  costs  in 
future  decades  at  $260/M  bd.  ft.  and  where  timber 
values  are  increasing.  The  revenues  would  be  the 
amounts  distributed  to  counties  and  the  federal 
treasury. 


Discount 

Rate 

4% 

Increase  in 

the  Value  of 

Timber 

1981  Price  level 

Plant  Improved 

of  $260/M 

Stock,  Final 

bd.  ft 

Harvest 

1.65  Annual 
Price  Apprecia- 
tion 1981-2030 


1  65  Annual 
Price  Apprecia- 
tion 1981 
Forward 


Plant  Improved 

Stock, 

Precommercial 

Thin, 

Fertilize, 

Final  Harvest 

Plant  Improved 
Stock,  Precom- 
mercial Thin. 
Fertilize,  Com- 
mercial Thin, 
Final  Harvest 


7.625% 


Plant  Improved 
Stock,  Final 
Harvest 

Plant  Improved 
Stock,  Final 
Harvest 


Plant  Improved 
Stock,  Precom- 
mercial Thin. 
Fertilize,  Com- 
mercial Thin, 
Final  Harvest 


10% 


Plant  Improved 
Stock,  Final 
Harvest 

Plant  Improved 
Stock.  Final 
Harvest 


Plant  Improved 
Stock,  Precom- 
mercial Thin, 
Fertilize,  Final 
Harvest 


164 


Table  B-3  Decadal  Budget  Requirements  and  Prospective  Revenues  of  the 
New  Preferred  Alternative  (Alt.  9) 
(millions  of  1980  dollars) 


Revenues  @ 

Net  Return 

1.65% 

@  1 .65% 

Annual 

Annual 

Increase 

Increase 

in  Timber 

in  Timber 

Budget  Re- 

Revenues  at 

Revenues  at 

Values 

Net  Return 

Net  Return 

Values 

scade 

>    quirements 

$94/MBF1 

S260/MBF' 

1980-2030 

at  $94/MBF  at  S260/MBF 

1980-2030 

1 

95.60 

232.18 

642.20 

723.84 

136.58 

546.60 

628.24 

2 

87.04 

221.78 

613.43 

820.26 

134.74 

526.39 

733.21 

3 

101.19 

204.50 

565.65 

897.33 

103.31 

464.46 

796.14 

4 

109.06 

173.75 

480.60 

929.37 

64.69 

371.54 

820.31 

5 

94.80 

72.87 

201.55 

699.83 

-21.93 

106.75 

605.03 

6 

86.13 

84.44 

233.56 

730.39 

-1.69 

147.43 

644.25 

7 

90.01 

70.55 

195.14 

719.18 

-19.46 

105.13 

629.17 

8 

89.33 

72.04 

199.25 

723.05 

-17.29 

109.93 

633.72 

9 

84.99 

68.44 

189.32 

698.44 

-16.55 

104.32 

613.45 

10 

83.62 

71.87 

198.78 

729.10 

-11.76 

115.15 

645.47 

11 

83.39 

82.54 

228.31 

789.51 

-0.85 

144.91 

706.11 

12 

79.17 

90.28 

249.71 

828.39 

11.11 

170.54 

749.22 

13 

75.98 

99.37 

274.85 

885.13 

23.39 

198.87 

809.15 

14 

69.25 

109.77 

303.61 

942.37 

40.52 

234.36 

873.12 

'Revenues  per  M  bd.  ft.  are  adjusted  by  the  average  diameter  of  harvest  and  the  average  volume  per  acre  and  based  on  current 
experience  and  utilization  standards. 


165 


Appendix  C 

Development  of  the  Proposed 

Action  and  Alternatives 

Defining  the  proposed  action  is  the  last 
phase  of  the  planning  process  prior  to  preparation 
of  the  EIS.  Alternatives  to  the  proposed  action  are 
identified  during  the  scoping  phase  of  the 
environmental  analysis  process.  Each  alternative 
analyzed  in  this  EIS  contains  a  mix  of  variables 
encompassing  a  range  of  choices  for 
decisionmakers  as  required  by  the  CEQ 
Regulations  (40  CFR  1502.2  (2)). 

In  determination  of  a  sustained  yield  allowable 
cut,  the  primary  variables  are  land  classification, 
acres  allocated  to  timber  production  and 
enhancement  of  growth  assumed  from  specific 
development  practices  or  treatments.  Following  in 
the  order  of  occurrence  are  brief  descriptions  of 
the  inventories  and  processes  employed  to 
determine  the  allowable  cut  level  for  the  proposed 
action  and  each  alternative. 

Land  Classification  and  Inventory 
Timber  Production  Capability 
Classification 

The  Timber  Production  Capability 
Classification  (TPCC)  is  an  intensive  inventory 
process  initiated  in  1972  to  categorize  all  public 
land  administered  by  BLM  in  western  Oregon 
based  upon  the  land's  physical  and  biological 
capacity  to  produce  timber.  TPCC  was  conducted 
in  accordance  with  Oregon  Manual  Supplement 
5250. 

The  TPCC  identified  402,000  acres  of  commercial 
forest  land  which  could  be  managed  on  a 
sustained  yield  basis.  Approximately  10,900  acres 
of  the  commercial  forest  land  were  determined  to 
be  incapable  of  undergoing  harvest  without 
significant  site  degradation.  These  lands, 
excluded  from  the  timber  production  base,  were 
placed  in  this  category  when  it  was  judged  that 
economically  reasonable  technology  was  not 
available  to  mitigate  such  degradation.  The 
remainder  of  the  SYUs'  21,900  acres  was 
determined  to  be  non-forest  or  non-commercial 
forest.  If  new  data  become  available  from  intensive 
on-site  analysis  or  improvements  occur  in 
technology,  the  classifications  may  be  altered. 

Operations  Inventory 

For  BLM  to  carry  out  the  timber  management 
program  effectively,  specific  information  as  to  the 
location  and  current  condition  of  the  various 
forest  types  within  the  land  base  must  be  available 
to  the  managers.  This  is  accomplished  through 
the  Operations  Inventory  (Ol)  in  accordance  with 
procedures  contained  in  the  Operations  Inventory 
Handbook  (STORMS). 


The  Ol  is  an  intensive  inventory  providing  forest 
type  maps  which  show  the  location  and 
classification  of  each  homogeneous  forest  type 
island.  Ol  record  cards  list  acreage,  silvicultural 
needs  and  opportunities  for  application  of  forest 
management  practices  on  each  type  island. 
Operations  Inventory  thus  provides  a  basis  for 
establishing  priorities  for  treatment  based  on 
stand  conditions  and  productivity. 

1978  Forest  Reinventory 

A  reinventory  of  commercial  forest  land  in 
the  SYUs  was  completed  in  1978  employing 
procedures  for  extensive  inventory  jointly 
developed  by  the  USFS  and  BLM  (USDA,  FS 
1976).  The  reinventory  uses  the  same  basic 
inventory  design  as  was  used  for  determination  of 
the  present  allowable  cut,  but  with  further 
refinement  to  include  stratification  of  commercial 
forest  land  based  on  information  obtained  from 
the  Ol  and  TPCC.  Statistical  analysis  indicates  the 
sample  mean  volume  per  acre  in  the  Roseburg 
SYUs  is  within  8  percent  of  the  true  mean  volume 
per  acre  at  one  standard  deviation. 

The  reinventory  indicates  a  forest  distribution  as 
displayed  in  Table  C-1.  Age  classes  range  from 
non-stocked,  where  reproduction  has  not  been 
established,  to  500  years. 


Table  C-1  Existing  Acres  by  Age 
Class  on  All  Forest  Lands 


Age 

Age 

Class 

Acres 

Class 

Acres 

Non- 

stocked 

7,403 

210 

5,849 

1-5 

26,740 

220 

5,649 

10 

40,853 

230 

25,085 

20 

36,568 

250 

12,291 

30 

13,852 

260 

4,348 

40 

5,973 

270 

1,504 

50 

9,065 

280 

2,294 

60 

11,319 

290 

1,301 

70 

8.959 

300 

13,799 

80 

10,931 

310 

6,882 

90 

11,741 

320 

2,294 

100 

13,282 

340 

2,294 

110 

16,879 

350 

2,294 

120 

20,008 

380 

4,588 

130 

3,595 

390 

2,294 

140 

3,595 

400 

2,294 

150 

10,545 

410 

2,294 

160 

5,616 

470 

2,294 

170 

6,197 

490 

742 

180 

21,947 

500 

6,882 

190 

8,305 

200 

3,592 

Total 

404,236 

166 


Other  Resource  Inventories 

Inventories  were  conducted  to  identify  and 
categorize  specific  capability  and  potential  of 
resources  other  than  timber.  Recreation  planners 
applied  the  BLM's  Recreation  Information  System, 
an  inventory  approach  for  determining  inherent 
potential  of  the  land  to  support  various  recreation 
activities.  Visual  resource  specialists  inventoried 
and  classified  the  SYUs  for  visual  and  esthetic 
considerations.  A  review  and  compilation  of 
known  cultural  resource  data  (Class  I  cultural 
resource  inventory)  has  been  completed.  Wildlife 
biologists  inventoried  northern  spotted  owl  and 
bald  eagle  nest  sites.  Fisheries  biologists 
conducted  surveys  of  streams  within  the  district. 
Botanical  surveys  for  threatened  and  endangered 
plants  were  initiated  for  the  Roseburg  District  in 
September  1978  and  are  updated  yearly.  A 
district-wide  soil  inventory  was  completed  by  Wert 
et  al.  1977  (see  References  Cited). 

Criteria  for  Selecting  the  Original 
Proposed  Action  (Alternative  4) 

The  following  criteria  were  used  by  the 
District  Manager  in  developing  the  Original 
Proposed  Action: 

•  Meet  the  long-term  objective  to  attain  a  high 
level  of  sustained  yield  timber  production  to 
satisfy  regional  and  national  needs. 

•  Minimize  soil  loss  caused  by  both  management 
activities  and  uncontrolled  activities  (e.g.,  off-road 
vehicles). 

•  Contribute  to  the  improvement  or  maintenance 
of  water  quality  in  streams,  rivers  and  municipal 
watersheds,  compared  to  current  conditions. 

•  Minimize  sediment  reaching  the  stream  and 
water  temperature  changes  that  occur  as  a  result 
of  management  activities. 

•  Minimize  impacts  on  air  quality  in  residential 
areas. 

•  Provide  for  developed  and  dispersed 
recreational  opportunities  to  meet  demands 
related  to  BLM-administered  lands. 

•  Provide  for  maintaining  the  visual  quality  of  the 
forest  landscape  in  areas  of  high  sensitivity. 

•  Protect  or  improve  and  develop  fish  spawning, 
rearing  and  migration  habitat. 

•  Protect  important  wildlife  habitat. 

•  Protect  or  enhance  habitat  of  threatened  or 
endangered  plant  and  animal  species. 

•  Provide  for  scientific  and  educational  study 
through  such  programs  as  Research  Natural 
Areas. 


•  Allow  minerals  exploration  and  development 
while  protecting  other  resource  values. 

•  Allow  adequate  land  allocations  for 
communication  sites,  access  development  and 
designation  of  right-of-way  corridors  while 
protecting  other  resource  values. 

•  Provide  local  economic  stability  through  high 
levels  of  local  employment  and  personal  earnings 
which  are  dependent  on  raw  materials,  recreation 
and  other  use  opportunities  available  on  lands 
administered  by  BLM. 

•  Provide  for  a  high  level  of  contribution  to  local 
public  revenues  from  resources  and  activities 
available  on  public  lands. 

•  Demonstrate  consistency  with  State  planning 
goals  (Land  Conservation  and  Development 
Commission),  acknowledged  local  comprehensive 
plans,  and  officially  approved  local  resource 
related  plans,  programs  and  policies. 

•  Demonstrate  consistency  with  other  Federal 
resource-related  plans,  programs,  and  policies. 
(Provide  coordinated  approach  to  regional  issues 
and  projects  or  proposals  crossing  administrative 
lines.) 

Land  Use  Allocation 

During  the  development  of  the  proposed  land 
use  allocations,  broad  land  use  alternatives  (MFP 
Alternatives)  were  identified  and  reviewed  by  the 
District  to  assess  their  effects.  These  MFP 
alternatives  were  circulated  for  public  review  and 
comment  in  1981.  Scoping  (see  Appendix  B)  of 
the  EIS  led  to  the  conclusion  that  four  of  these 
land  use  allocation  alternatives  (some  slightly 
modified)  were  important  enough  to  analyze  in 
depth.  The  resulting  land  use  allocations  by 
alternative  (Table  C-2)  were  adapted  from  those 
alternatives.  Alternatives  1,  4,  6  and  8  of  the  draft 
EIS  were  adapted  from  these  alternatives. 

Resource  protection  varies  by  alternative  relative 
to  the  mixture  of  land  use  allocations  and 
management  features  prescribed.  Table  C-3 
shows  acreage  allocations,  by  resource,  of  the 
MFP  withdrawals  and  constrained  timber 
production  bases.  Table  C-4  identifies  proposed 
management  features  applied  during  management 
of  the  timber  producing  lands  relative  to  the  level 
of  protection  provided  by  each  alternative. 

When  final  MFP  timber  management  decisions  are 
made,  they  will  form  the  management 
prescriptions.  Similarily,  actions  for  other 
resources,  e.g.,  habitat  management  plans,  will  be 
within  the  MFP  guidelines. 


167 


Table  C-2  Land  Use  Allocation  Proposed  for  the  EIS  Alternatives  (Acres) 


No  Planned  Timber  Harvest 

Non-Commercial  Forest  Land 
Non-Forest  Lands 
Fragile  Site  Withdrawals 
Reforestation  Withdrawals 
MFP  Withdrawals  2 


Alt.  1 

Alt.  2 

Alt.  3 

Alt.  4 

Alt.  5' 

Alt.  6 

Alt.  7 

Alt.  8 

Alt.  9 

Max.  Tbr. 

Emp.  Tbr. 

LoMHS 

OPA 

No  Action 

HD 

No  Herb. 

Full  Eco. 

NPA 

2,259 


2.259 


2,259 


2,259 


14,304 


2,259 


2,259 


2,259 


2,259 


19,660 

19,660 

19,660 

19,660 

18,204 

19,660 

19,660 

19,660 

19,660 

2,614 

2,614 

2,614 

2,614 

0 

2,614 

2,614 

2,614 

2,614 

8,293 

8,293 

8,293 

8,293 

0 

8,293 

80,421 

8,293 

8,293 

4,448 

5,704 

5,704 

5,704 

404 

48,790 

5,704 

128,634 

23,565 

Sub-total 


37,274 


38,530 


38,530 


38,530 


32,912 


81,616       110,658       161,460 


56,391 


Planned  Timber  Harvest 

Intensive  Base 


Constrained  Base 

VRM 

Wildlife 


386,622 

360,580 

333,319 

333,319 

377,098 

222,357 

261,191 

0 

331.637 

0 

3,682 

2,646 

2,646 

5,812 

31,345 

2,646 

49,376 

2,658 

0 

21,104 

49,401 

49,401 

8,074 

88,579 

49,401 

213,060 

33,210 

Sub-total 

Total  SYUs  Acres 


386,622       385,366       385,366       385,366       390,984       342,281       313,238       262,436       367,505 
423,896       423,896       423.896       423,896       423,896       423,896       423,896       423,896       423,896 


1  Land  use  allocations  for  Alternative  5  (No  Action)  resulted  from  the  land  classification  instructions  used  in  the  1970  planning 
process.  For  example,  fragile  sites  and  reforestation  withdrawal  are  contained  in  the  non-commercial  forest  land  category. 

2  These  are  commercial  forest  lands  withdrawn  from  the  timber  production  base  for  other  resourc  considerations.  See  Table  C-3 
for  the  identified  resource  and  acres  allocated. 


Table  C-3  Acreage  Allocation  by  Resource 


Alt.  1 
Max.Tbr. 

Alt.  2 
Emp. Tbr. 

Alt.  3 
LoMHS 

Alt.  4 
OPA 

Alt.  5 
No  Action 

Alt.  6 
HD 

Alt.  7 
No  Herb. 

Alt.  8 
Full  Eco. 

Alt.  9 
NPA 

611 
508 
502 

611 

508 

1,185 

611 

508 

1,185 

611 

508 

1,185 

0 

0 

404 

570 

508 

2,773 

611 

508 

1,185 

570 

508 

4,615 

611 

508 

1,185 

2,912 
0 
0 
0 
0 

2,912 

640 

0 

0 

0 

2,912 

640 

0 

0 

0 

2,912 

640 

0 

0 

0 

0 
0 
0 
0 
0 

2.769 

1,280 

21,422 

26,383 

0 

2,912 

640 

0 

0 

0 

0 

2,560 

40,098 

90,707 

0 

2,699 

640 

0 

18.332 

0 

Resource  Considerations  in 
Acres  * 

MFP  WITHDRAWALS 

Botanical 

Cultural 

Recreation1 

Wildlife: 
Bald  Eagle 

Golden  Eagles  &  Raptors 
Old  Growth  Blocks 
Riparian  Areas 
VRM  II 

CONSTRAINED  TIMBER  PRODUCTION 
BASE 

Visual  Resource  Management 

Wildlife: 
Bald  Eagle 

Northern  Spotted  Owl 
Old  Growth  Blocks 
80  Acre  Blocks 
Osprey 
Riparian  Areas 

"Acres  are  not  additive  due  to  overlap. 

'  Includes  developed  sites,  recreation  facilities,  research  natural  areas,  outstanding  natural  areas  and  in  Alternatives  6  and  8  sites 
pending  suitability  studies. 


8,383 


8,383 


8,383 


5.812 


45,703 


8,383 


90.703 


8.383 


0 

0 

0 

0 

0 

0 

0 

8.769 

0 

0 

0 

19,826 

19,826 

0 

27,407 

19,826 

54,940 

20.321 

0 

0 

14,700 

14,700 

0 

0 

14,700 

0 

16,780 

0 

0 

10,582 

10,582 

0 

67,727 

10,582 

102,466 

11,370 

0 

3,445 

3,445 

3,445 

0 

5,273 

3,445 

10,430 

3.058 

0 

18,332 

18,332 

18,332 

8,074 

0 

18,332 

0 

0 

168 


Table  C-4  Management  Features 


Resource  Feature 


WILDLIFE 

AIM 

All. 2 

Alt. 3 

Alt.4 

Alt. 5 

Alt. 6 

Alt. 7 

Alt. 8 

Alt.  9 

Max.  Tbr. 

Emp.  Tbr. 

Lo  MHS 

OPA 

No  Action 

HD 

No  Herb. 

Full  Eco. 

NPA 

Riparian  Zones 

No  timber 

No  restriction 

Same  as  »2 

Same  as  #2 

No  harvest 

No  harvest 

Same  as  »2 

Complete 

No  harvest 

harvest 

on  1st  and  2nd 

restriction  on 

restriction  on 

protection  on 

restriction  on 

restrictions 

order  streams. 

1st  and  2nd 

1st  and  2nd 

all  stream 

1st  and  2nd 

Approximately 

order  streams 

order  streams; 

orders,  totaling 

order  streams. 

18.300  acres 

An  estimated 

an  estimated 

approximately 

an  estimated 

along  3rd  order 

8,070  acres 

26,400  acres 

90.700  acres. 

18.300  acres 

and  larger 

along  3rd  order 

along  3rd  order 

along  3rd  order 

streams  would 

and  larger 

and  larger 

and  larger 

be  managed 

streams  would 

streams  would 

streams  would 

under  modified 

receive 

receive 

receive 

area  control. 

protection. 

complete 

complete 

Harvest  is 

protection 

protection. 

expected  to 

occur  on  an 

estimated  6% 

of  this  area,  of 

which  11% 

would  be 

clearcut. 

Snags  (#/acre) 


Northern 
Spotted  Owls 

Managed  for 

(pairs) 


None  on  6/acre  in 

intensive  modified  area 

timber  base  control  3/ac. 

6/acre  on  other  on  remainder 
forest  lands 


Same  as  #3 


Non  on 
intensive  base 
3/ac.  on  other 
forest  land 


2/acre  on  25%      Same  as  #3 

of  intensive 

outside  of  old 

growth  areas 

3/ac  on  old 

growth  and 

other  land  with 

no  planned 

timber  harvest. 


25 


3/acre  on  35%      Same  as  #3 

of  land  base 

outside  of  old 

growth  areas. 

3/acre  on  old 

growth  and 

other  lands 

with  no 

planned  timber 

harvest. 


55 


19 


Spacing 
Between 
Clearcuts  (year) 


3-5 


3-5 


5  year  on 
intensive  base 
variable  in 
modified  area 
control 


Same  as  #3 


3-5 


10 


Same  as  #3 


Same  as  #3 


Modified  Area 
Control  (acres) 

0 

24,800 

52.050 

52,050 

0 

0 

52.050 

0 

35.868 

RECREATION 

Potential 
Recreation 
Sites  (#) 

3 

12 

12 

12 

0 

8 

12 

8 

12 

Natural  Areas 
(potential)  (#) 
(designated)  (#) 

0 
2 

6 
2 

6 
2 

6 
2 

0 
2 

6 
2 

6 

2 

6 
2 

6 
2 

Areas  of  Critical 
Environmental 
Concern 
(number/acres) 

4/600 

4/2.100 

4/2.100 

4/2,100 

0 

8/3,100 

4/2.100 

8/3.100 

4/2,100 

Visual  Resource 
Management 
Classes  (acres) 

I 

II 

III 

IV 

30 

2.400 

400 

421.170 

30 

9.300 

13.600 

401.070 

30 

9.300 

13,600 

401,070 

30 

9.300 

13.600 

401.070 

30 

1.100 

3,000 

419.870 

30 

26,600 

22,400 

374.970 

30 

9.300 

13.600 

401.070 

30 

75,700 

22,900 

325.370 

30 

30 

13.600 

401,070 

169 


Modified  Area  Control 

Modified  area  control  is  a  process  for 
managing  a  given  number  of  acres  under  a  special 
timber  harvest  regime.  In  the  Roseburg  District, 
52,047  acres  are  proposed  to  be  managed  under 
the  modified  area  control  concept  for  Alternatives 
3,  4  and  7,  35,868  acres  for  Alternative  9  and 
24,786  acres  for  Alternative  2.  Harvest  methods 
and  volumes  will  vary,  ranging  from  clearcut  to 
individual  tree  selection,  depending  on  the 
particular  resource  involved,  the  degree  of 
protection  necessary  and  the  silvicultural  system 
used. 

Although  in  practice  not  every  area  would  be  cut, 
for  purposes  of  calculating  allowable  cut  yields,  it 
was  assumed  the  entire  acreage  would  be 
managed  oh  a  250  year  harvest  age.  The  volume 
to  be  harvested  during  the  first  decade  under  this 
concept  was  calculated  manually,  and  the  result 
was  tested  using  SIMIX  to  ensure  sustainability. 
Approximately  9  MM  bd.  ft.  would  be  scheduled 
for  harvest  from  these  areas  each  year,  except  in 
Alternative  2,  where  modified  area  control  harvest 
would  be  approximately  4  MM  bd.  ft,  and 
Alternative  9,  where  harvest  would  be 
approximately  6  MM  bd.  ft.  In  actual  practices,  the 
volume  generated  would  probably  be 
concentrated  during  the  last  half  of  the  decade, 
rather  than  occurring  as  a  constant  annual  flow. 
This  is  caused  by  the  necessity  to  complete 
detailed  habitat  and  visual  management  plans  on  a 
number  of  these  areas  prior  to  scheduling  timber 
harvests. 

Forest  land  acres  and  age  class  distribution  were 
determined  individually  for  the  allocations  to 
benefit  each  resource.  A  listing  of  lands  proposed 
for  modified  area  control  was  developed  as 
follows: 


Resource  Allocation 

Mid-age  and 
Old  Growth 
Riparian 
VRM  II 

TOTAL 


Comi 

mercial  Forest  Land 
Acres1 

Alt.  2 

Alts.  3, 
4&  7 

Alt.  9 

2,772 

18,332 

3,682 

32,882 

16,519 

2,646 

33,210 

0 

2,658 

24,786  52,047 


35,868 


'  Overlaps  between  resource  allocations  were  eliminated. 


Mid-age  and  old-growth  is  located  in  loosely 
arranged  corridors.  Ties  with  corridors  in 
adjoining  BLM  districts  are  incorporated.  These 
components  also  include  functioning  old  growth 
systems  distributed  by  seed  zone  and  elevation  in 
order  to  safeguard  long  term  timber  productivity 
(see  Serai  Stage  Distribution  Concept,  Appendix 
A). 


That  portion  of  the  allocated  mid-age  and  old 
growth  which  exists  as  80-acre  blocks  would  be 
managed  to  maintain,  as  a  minimum,  70  percent  of 
these  blocks  in  the  120+  age  class.  Normally, 
management  would  be  to  harvest  the  entire 
selected  block  within  a  decade  to  create  an  even- 
age  stand,  thereby  attaining  desired  wildlife  values 
in  the  future. 

Osprey  and  heron  habitat  would  be  managed  with 
seasonal  harvest  limitations  to  avoid  disturbance 
of  nesting  pairs.  When  osprey  and  heron  habitat 
overlaps  visual  protection  areas,  timber  harvest 
would  be  managed  in  conjunction  with  VRM  plans 
to  maintain  visual  quality.  Harvest  in  VRM  II  zones 
would  be  conducted  according  to  the  sequential 
settings  delineated  in  the  visual  resource 
management  plans.  All  visual  plans  are  scheduled 
for  completion  by  1989. 

Modified  Area  Control  on  Riparian 
Areas 

For  Alternatives  2,  3,  4  and  7  approximately 
18,300  acres  of  riparian  areas  along  third  order 
and  greater  streams  would  be  managed  in 
vegetative  buffers  averaging  200  feet  wide.  This 
includes  the  actual  riparian  habitat  (10,650  acres) 
shown  in  Chapter  2  plus  additional  transitional 
vegetation  (7,650  acres).  These  areas  would  be 
managed  to  provide  riparian  values,  including 
habitat  structure  important  to  cavity  dwellers  and 
other  species,  to  maintain  shade  and  woody 
structure  important  to  fish  habitat  and  to  protect 
stream  bank  stability  for  water  quality  and 
temperature  control. 

Prior  to  timber  management  activities  in  these 
areas,  site  specific  interdisciplinary  plans  would 
be  completed  to  delineate  riparian  values  as  well 
as  appropriate  harvest  levels  and  project  design 
features. 

In  riparian  areas,  clearcuts  would  be  permitted  for 
road  crossings,  yarding  corridors  and  harvest  of 
small  isolated  parcels.  This  would  permit  access 
to  the  majority  of  the  district  land  base,  while 
minimizing  impacts  to  a  small  portion  of  the 
riparian  area.  According  to  the  sample  5-year 
timber  sale  plan,  approximately  12  acres  of 
riparian  vegetation  would  be  clearcut  each  year. 

In  addition,  the  sample  5-year  timber  sale  plan 
includes  approximately  96  acres  that  would  be 
partial  cut  each  year.  In  partial  cut  areas, 
silvicultural  systems  ranging  from  individual  tree 
selection  to  group  selection  or  shelterwood  would 
be  used. 

The  remaining  areas  of  riparian  vegetation  are  not 
planned  for  entry  during  the  first  decade. 

Management  practices  which  would  be  applied  to 
riparian  areas  (including  streamside  buffers) 
include  directional  falling  of  timber  away  from 


170 


streams,  no  machinery  operation  in  streams 
(except  for  road  construction,  e.g.,  bridges  and 
culverts)  and  full  suspension  yarding  across 
riparian  management  areas.  No  burning  would  be 
conducted  in  the  riparian  management  areas. 

As  information  and  greater  understanding 
regarding  the  management  of  these  areas  are 
gained  throughout  the  decade,  necessary 
revisions  would  be  incorporated  into  the  next 
planning  cycle. 

Allowable  Cut  Computation 
Forest  Simulation  Model 

A  computerized  forest  simulation  model 
(SIMIX)  is  used  to  determine  the  highest 
sustainable  allowable  cut  for  each  alternative. 
SIMIX  calculates  the  allowable  cut  associated  with 
the  stated  forest  management  plan.  It  can 
maximize  an  even-flow  level  of  cut  for  some 
specific  management  regime,  or  a  series  of  cut 
levels  may  be  specified  for  as  many  as  the  first  10 
decades  followed  by  an  even-flow  level  for  the 
remainder  of  the  projected  period  (40  decades). 
This  lengthy  projection  period  is  not  an  attempt  at 
a  400-year  plan.  It  is  used  only  to  assure  that  the 
condition  of  no  planned  reduction  in  allowable  cut 
can  be  met. 

The  clearcut  option  of  SIMIX  was  utilized  since 
clearcut  is  the  predominant  harvest  method  in  all 
alternatives.  For  accuracy  in  measuring  lumber 
and  plywood  production,  the  allowable  cut  is 
computed  and  projected  into  the  future  on  the 
basis  of  cubic  feet. 

SIMIX  computes  the  harvest  level  based  on 
present  inventory  and  projected  growth  resulting 
from  the  application  of  certain  management 
practices  (mortality  salvage,  precommercial  and 
commercial  thinning,  commercial  thinning  only, 
forest  genetics  and  final  harvest  cuts).  Another 
treatment,  fertilization,  is  included  in  conjunction 
with  one  or  more  of  the  above  treatments.  SIMIX 
must  be  told  what  treatments,  when  and  the 
number  of  acres,  to  be  treated.  No  rotation  age  is 
set;  instead,  a  minimum  cutting  age  constraint  is 
specified.  SIMIX  is  not  designed  to  handle 
economic  values  or  costs,  and  it  does  not  seek  out 
alternative  schedules  or  strategies. 

The  model,  designed  for  forests  under  an  even- 
aged  system  of  management,  produces  output 
data  by  decades  for  each  age  and  treatment  class 
and  summarizes  them  numerically  and 
graphically.  These  data  include  level  of  growing 
stock,  annual  growth,  acreage  by  silvicultural 
practices  and  volume  by  harvesting  practice. 
Consequently,  it  permits  alternative  plans  to  be 
evaluated  on  the  basis  of  their  respective 
production  levels  and  fiscal  requirements  and 
serves  as  a  basis  for  programming  personnel  and 
funds  for  the  alternative  selected.  In  effect,  a 


management  plan  is  developed  that  schedules  the 
production  from  commercial  thinning,  mortality 
salvage  and  final  harvest  operations  and  also  the 
acreages  for  such  treatments  as  reforestation  and 
precommercial  thinning.  The  model  is  geared  to 
the  proposed  policies  but  is  flexible  to  the  extent 
that  other  regulatory  policies  can  be  applied  in  its 
use. 

The  Allowable  Cut  Effect  (ACE) 

A  forest  that  is  composed  primarily  of 
old-growth  timber  and  recently  cut-over  stands 
exhibits  a  relatively  low  average  annual  growth. 
This  results  from  slow  or  negative  growth  of  the 
old  stands  and  the  fact  that  growth  is  not 
measurable  (in  end-product  terms)  in  the  young 
stands  until  they  reach  20  or  30  years  of  age.  Such 
a  forest  is  in  transition  from  an  unmanaged  to  a 
managed  or  regulated  state.  In  the  classical  sense, 
the  regulated  state  is  achieved  when  average 
annual  harvest  and  growth  are  in  equilibrium.  At 
this  point,  maximum  yield  on  a  sustainable  basis  is 
reached.  To  compute  an  allowable  cut  on  a  forest 
in  the  transition  state  using  this  criteria  would  be 
extremely  conservative  and  greatly  lengthen  the 
time  until  the  regulated  state  was  achieved.  The 
BLM  uses  an  alternative  approach  which  is  to 
project  growth  into  the  future  based  upon 
assumptions  about  management  levels  and  to 
utilize  excess  harvest  age  timber  to  bridge  the 
time  gap  until  the  ultimate  growth  level  is 
achieved.  This  process  of  taking  credit  now  for 
future  growth  increases  expected  to  result  from 
management  has  been  termed  the  "Allowable  Cut 
Effect"  (ACE). 

Figure  C-1  illustrates  this  process  in  the  context  of 
conditions  found  in  the  SYUs,  before  land  use 
allocations  were  made  to  other  resource  activities. 

This  forest  is  in  the  early  to  middle  transition  stage 
and,  as  the  recent  inventory  found,  has  a  relatively 
low  average  annual  growth  rate.  An  initial 
computation  was  made  that  assumed  no  intensive 
management  practices  were  performed.  Under 
this  scheme,  stands  were  projected  to  grow  in  a 
fashion  similar  to  normal  unmanaged  forests.  The 
lower  growth  curve  in  Figure  C-1  shows  the 
average  annual  growth  path  projected  from  these 
assumptions.  When  tested  on  the  allowable  cut 
model,  it  was  determined  that  sufficient  harvest 
age  timber  was  available  to  bridge  the  gap  until  a 
regulated  state  was  achieved. 

Next,  a  high  level  of  management  was  assumed. 
Practices  (see  Chapter  1,  Forest  Management 
Treatments  and  Design  Elements)  such  as  genetic 
improvement,  precommercial  and  commercial 
thinning,  fertilization  and  mortality  salvage  were 
used  in  projecting  yield  functions.  The  basis  for 
most  of  these  projections  was  the  DFIT  model. 
The  higher  growth  curve  in  Figure  C-1  shows  the 
average  annual  growth  path  resulting  from  the 
intensive  management  assumptions.  When  tested 


171 


on  the  allowable  cut  model,  it  was  determined  that 
there  was  only  enough  harvest  age  timber 
available  to  take  credit  for  a  portion  of  the 
expected  future  growth  increases.  For  full  ACE 
credit  to  apply,  there  must  be  enough  harvestable 
timber  to  bridge  the  previously  mentioned  time 
gap.  Since  this  was  not  the  case  in  the  Roseburg 
SYUs,  the  allowable  cut  effect  applied  was  limited 
to  about  53  percent  of  the  projected  potential 
allowable  cut  effect.  To  set  a  cut  level  higher  than 
the  "actual"  would  cause  a  drop  in  future  cut 
levels,  a  violation  of  Bureau  policy.  The  foregoing 
narrative  is  supplemented  by  Figure  C-2  which 
portrays  both  data  source  and  information  flow 
sequence  for  the  allowable  cut  determination 
process. 


FIGURE  C-l 
ALLOWABLE  CUT  EFFECT 


ALLOWABLE 

CUT 

POTENTIAL  HARVEST 

WITH  INTENSIVE  MANAGEMENT 

EFFECT 

Ul 

A 

> 

,  • 

T 

cr 

.' 

< 

t»" 

i 

i 

< 

Q 

ACTUAL  HARVEST 

WITH  INTENSIVE  MANAGEMENT 

• 
« 

J 

< 

t 
« 

H 

(L 

I 

HARVEST 

• 

WITHOUT  INTENSIVE  MANAGEMENT 

1_ 

i 

O 

cr 

*                                    4.  • 

o 

,* 

,.* 

_i 

#«" 

• 

< 

i  * 

.  •  * 

3 

,  * 

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Z 
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Figure  C-2 


Bureau  Planning  System 
All  Resource  Data 


Allowable  Cut  Planning  System 
Forestry  Data 


Policy,  Guidance, 
Socio-economic  Data 


Resource  Analysis 
Existing  Situation 

•  Present  forest  condition 


Summary  Data 


Opportunities 

Initial  decade  treated  acres  by  intensive  management  practice 
Ultimate  acreage  to  undergo  Intensive  management 
Yields  for  each  intensive  management  practice 


1 


Management  Framework  Plans 

•  Select  forest  management  practices  which  meet  the  test 
of  environmental  and  economic  feasibility 


Forest  Management  Policy 
minimum  harvest  age 


District  Inputs 


i—        Forest  Reinventory 


Timber  Production 
Capability  Classification 


Regeneration  Lag 


Emperic  and  Non-treated 
Yield  Curves  (DFIT) 


Final  Harvest  Acres 
by  Cutting  Practice 


Young  Growth  Management  Committee  Report 
Feasible  and  unfeasible  intensive  management  practices 


Operations  Inventory 
Forest  Stand  Development  Opportunities 


Land  Use  Allocation  -  Acres 
Decisions  resolving  conflicting  opportunities 

•  Based  on  tests  of  various  multiple  use  constraints 


Environmental  Impact  Statement 

Draft  and  final  documents  analyze  impacts  of  proposed 
action  and  other  alternatives 


Decision 
Allowable  cut  declared,  management  framework  plan 
implemented 


Simix  Model 

Inputs: 

•  Acreage  and  age  class  distribution  in  allowable  cut  land  base' 

•  Minimum  harvest  age' 

•  Acreages  to  be  treated  during  initial  decade  by  intensive  management' 

•  Ultimate  acreage  to  undergo  intensive  management' 

•  Empirical  and  non-treated  yields' 

•  Yields  for  each  intensive  management  practice' 

•  Regeneration  lag 

•  Acreage  removed  from  the  timber  production  base  by  decade  due  to  roading 

•  Acreage  constrained  because  of  multiple  use  consideration 

•  Acreage  foregone  because  of  multiple  use  consideration 

Outputs: 

Decadal  printout  covering  40  decades  contains 

•  Even  flow  volume 

•  Age  class  distribution 

•  Acreages  for  PCT 

•  Acreages  and  volumes  for  commercial  thinning,  morlality  salvage  and  final 
harvest 

•  Growth  and  standing  volumes 

'Primary  determinants  of  the  degree  of  allowable  cut  effect 


Appendix  D  Wildlife 


173 


Conifer  Habitat 


Other  Habitat 


Key 

Resident  Habitat 

P=Permanent  U=Uses 

S=Summer  0=Optimum 

W=Winter 
M=Migratory 

Relative  Abundance 

A=Abundant 
C=Common 
U=Uncommon 
R=Rare 

Mammals 

Virginia  Opossum  (Didelphis  virginiana) 

Vagrant  Shrew  (Sorex  vagrans) 

Dusky  Shrew  (Sorex  obscurus) 

Pacific  Shrew  (Sorex  pacificus) 

Virginia  Opossum  (Didelphis  virginiana) 

Vagrant  Shrew 

Water  Shrew  (Sorex  palustris) 

Pacific  Water  Shrew  (Sorex  bendirii) 

Trowbridge's  Shrew  (Sorex  trowbridgii) 

Shrew-mole  (Neurotrichus  gibbsii) 

Townsend's  Mole  (Scapanus  townsendii) 

Coast  Mole  (Scapanus  orarius) 

Little  Brown  Myotis  (Myotis  lucifugus) 

Yuma  Myotis  (Myotis  yumanensis) 

Long-eared  Myotis  (Myotis  evotis) 

Fringed  Myotis  (Myotis  thysanodes) 

Long-legged  Myotis  (Myotis  volans) 

California  Myotis  (Myotis  californicus) 

Silver-haired  Bat  (Lasionycteris  noctivagans) 

Big  Brown  Bat  (Eptesicus  fuscus) 

Hoary  Bat  (Lasiurus  cinereus) 

Townsend's  Big-eared  Bat  (Plecotus  townsendii) 

Pallid  Bat  (Antrozous  pallidus) 

Brazilian  Free-Tailed  Bat  (Tadarida  brasiliensis) 

Pika  (Ochotona  princeps) 

Brush  Rabbit  (Sylvilagus  bachmani) 

Snowshoe  Hare  (Lepus  americanus) 

Black-tailed  Jackrabbit  (Lepus  californicus) 

Mountain  Beaver  (Aplodentia  rufa) 

Townsend's  Chipmunk  (Eutamias  townsendii) 

California  Ground  Squirrel  (Spermophilus  beecheyi) 

Western  Gray  Squirrel  (Sciurus  griseus) 

Douglas'  Squirrel  (Tamiasciurus  douglasii) 

Northern  Flying  Squirrel  (Glaucomys  sabrinus) 

Botta's  Pocket  Gopher  (Thomomys  bottae) 

Western  Pocket  Gopher  (Thomomys  mazama) 

Beaver  (Castor  canadensis) 

Deer  Mouse  (Peromyscus  maniculatus) 

Dusky-footed  Woodrat  (Neotoma  fuscipes) 

Bushy-tailed  Woodrat  (Neotoma  cinerea) 

Western  Red-backed  Vole  (Clethrionomys  occidentalis) 

White-footed  Vole  (Phenacomys  albipes) 

Red  Tree  Vole  (Phenacomys  longicaudus) 

California  Vole  (Microtus  californicus) 

Townsend's  Vole  (Microtus  townsendii) 

Long-tailed  Vole  (Microtus  longicaudus) 

Creeping  Vole  (Microtus  oregoni) 

Muskrat  (Ondatra  zibethicus) 

Norway  Rat  (Rattus  norvegicus) 

House  Mouse  (Mus  musculus) 

Pacific  Jumping  Mouse  (Zapus  trinotatus) 

Porcupine  (Erethizon  dorsatum) 

Nutria  (Myocaster  coypus) 

Coyote  (Canis  latrans) 

Red  Fox  (Vulpes  vulpes) 

Gray  Fox  (Urocyon  cinereoargenteus) 


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174 


Appendix  D  Wildlife  (continued) 


Conifer  Habitat 


Key 

Resident  Habitat 

P=Permanent  U=Uses 

S=Summer  0=Optimum 

W^Winter 
M-Migratory 

Relative  Abundance 

A=Abundant 
OCommon 
U^Uncommon 
R=Rare 


Black  Bear  (Ursus  americanus) 

Ringtail  (Bassariscus  astutus) 

Raccoon  (Procyon  lotor) 

Marten  (Martes  americana) 

Fisher  (Martes  pennanti) 

Ermine  (Mustela  erminea) 

Long-tailed  Weasel  (Mustela  frenata) 

Mink  (Mustela  vison) 

Western  Spotted  Skunk  (Spilogale  gracilis) 

Striped  Skunk  (Mephitis  mephitis) 

River  Otter  (Lutra  canadensis) 

Mountain  Lion  (Felis  concolor) 

Bobcat  (Felis  rufus) 

Roosevelt  Elk  (Cervus  elaphus  rooseveltii) 

Columbian  Black-tailed  Deer 

Odocoileus  hemionus  columbianus) 
Columbian  White-tailed  Deer 

(Odocoileus  Virginians  leucurus) 

Birds 

Common  Loon  (Gavia  immer) 

Eared  Grebe  (Podiceps  nigricollis) 

Western  Grebe  (Aechmophorus  occidentalis) 

Pied-billed  Grebe  (Podilymbus  podiceps) 

Double-crested  Cormorant  (Phalacrocorax  auritus) 

Great  Blue  Heron  (Ardea  herodias) 

Green  Heron  (Butorides  striatus) 

Great  Egret  (Casmerodius  albus) 

Black-crowned  Night  Heron  (Nycticorax  nycticorax) 

American  Bittern  (Botarus  lentiginosus) 

Whistling  Swan  (Olor  columbianus) 

Canada  Goose  (Branta  canadensis) 

White-fronted  Goose  (Anser  albifrons) 

Snow  Goose  (Chen  caerulescens) 

Mallard  (Anas  platyrhynchos) 

Gadwall  (Anas  strepera) 

Pintail  (Anas  acuta) 

Green-winged  Teal  (Anas  crecca) 

Blue-winged  Teal  (Anas  discors) 

Cinnamon  Teal  (Anas  cyanoptera) 

American  Wigeon  (Anas  americana) 

Northern  Shoveler  (Anis  clypeata) 

Wood  Duck  (Aix  sponsa) 

Redhead  (Aythya  americana) 

Ring-necked  Duck  (Aythya  collaris) 

Canvasback  (Aythya  valisineria) 

Greater  Scaup  (Aythya  marila) 

Lesser  Scaup(Aythya  affinis) 

Common  Goldeneye  (Bucephala  clangula) 

Bufflehead  (Bucephala  albeola) 

Ruddy  Duck  (Oxyura  jamaicensis) 

Hooded  Merganser  (Lophodytes  cucullatus) 


Other  Habitat 


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Appendix  D  Wildlife  (continued) 


175 


Conifer  Habitat 


Other  Habitat 


Key 

Resident  Habitat 

P=Permanent  U^Uses 

S=Summer  OOptimum 

W=Winter 
M=Migratory 

Relative  Abundance 

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Common  Merganser  (Mergus  Merganser) 
Red-breasted  Merganser  (Mergus  serrator) 
Turkey  Vulture  (Cathartes  aura) 
Northern  Goshawk  (Accipiter  gentilis) 
Sharp-shinned  Hawk  (Accipiter  striatus) 
Cooper's  Hawk  (Accipiter  cooperi) 
Red-tailed  Hawk  (Buteo  jamaicensis) 
Rough-legged  Hawk  (Buteo  lagopus) 
Golden  Eagle  (Aquila  chrysaetos) 
Bald  Eagle  (Haliaeetus  leucocephalus) 
Northern  Harrier  (Circus  cyaneus) 
Osprey  (Pandion  haliaetus) 
Prairie  Falcon  (Falco  mexicanus) 
Merlin  (Falco  columbarius) 
American  Kestrel  (Falco  sparverius) 

Blue  Grouse  (Dendragapus  obscurus) 

Ruffed  Grouse  (Bonasa  umbellus) 

California  Quail  (Lophortyx  californicus) 

Mountain  Quail  (Oreortyx  pictus) 

Ring-necked  Pheasant  (Phasianus  colchicus) 

Virginia  Rail  (Rallus  limicola) 

Sora  (Porzana  Carolina) 

American  Coot  (Fulica  americana) 

Semi-palmated  Plover  (Calidris  pusilla) 

Killdeer  (Charadrius  vociferus) 

Common  Snipe  (Capella  gallinago) 

Spotted  Sandpiper  (Actitis  macularia) 

Solitary  Sandpiper  (Tringa  solitaria) 

Greater  Yellowlegs  (Tringa  melanoleucus) 

Lesser  Yellowlegs  (Tringa  flavipes) 

Least  Sandpiper  (Calidris  minutilla) 

Long-billed  Dowitcher  (Limnodromus  scolopaceus) 

Dunlin  (Calidris  alpina) 

Western  Sandpiper  (Calidris  mauri) 

Short-billed  Dowitcher  (Limnodromus  griseus) 

Northern  Phalarope  (Lobipes  lobatus) 

Glaucous-winged  Gull  (Larus  glaucescens) 

Western  Gull  (Larus  occidentalis) 

Herring  Gull  (Larus  argentatus) 

California  Gull  (Larus  californicus) 

Ring-billed  Gull  (Larus  delawarensis) 

Band-tailed  Pigeon  (Columba  fasciata) 

Rock  Dove  (Columba  livia) 

Mourning  Dove  (Zengida  macroura) 
Barn  Owl  (Tyto  alba) 
Screech  Owl  (Otus  asio) 
Great  Horned  Owl  (Bubo  virginianus) 
Snowy  Owl  (Nyctea  scandiaca) 
Pygmy  Owl  (Glaucidium  gnoma) 
Northern  Spotted  Owl  (Strix  occidentalis) 
Short-eared  Owl  (Asio  flammeus) 
Saw-whet  Owl  (Aegolius  acadicus) 


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176 


Appendix  D  Wildlife  (continued) 


Conifer  Habitat 


Other  Habitat 


Key 

Resident  Habitat 

P=Permanent  LNUses 

S=Summer  0=Optimum 

W=Winter 
M=Migratory 

Relative  Abundance 

A-Abundant 
C=Common 
U-Uncommon 
R=Rare 


Common  Nighthawk  (Chordeiles  minor) 
Vaux's  Swift  (Chaetura  vauxi) 
Anna's  Hummingbird  (Calypte  anna) 
Rufous  Hummingbird  (Selasphorus  rufus) 
Belted  Kingfisher  (Megaceryle  alcyon) 
Common  Flicker  (Colaptes  auratus) 
Pileated  Woodpecker  (Dryocopus  pileatus) 
Acorn  Woodpecker  (Melanerpes  formicivorus) 
Lewis  Woodpecker  (Melanerpes  lewis) 
Yellow-bellied  Sapsucker  (Sphyrapicus  varius) 
Hairy  Woodpecker  (Picoides  villosus) 
Downy  Woodpecker  (Picoides  pubescens) 
Western  Kingbird  (Tyrannus  verticalis) 
Ash-throated  Flycatcher  (Myiarchus  cinerascens) 
Willow  Flycatcher  (Empidonax  traillii) 
Hammond's  Flycatcher  (Empidonax  hammondii) 
Dusky  Flycatcher  (Empidonax  oberholseri) 
Western  Flycatcher  (Empidonax  difficilis) 
Western  Wood  Pewee  (Contopus  sordidulus) 
Olive-sided  Flycatcher  (Nuttallornis  borealis) 
Violet-green  Swallow  (Tachycineta  thalassina) 
Tree  Swallow  (Iridoprocne  bicolor) 
Bank  Swallow  (Riparia  riparia) 
Rough-winged  Swallow  (Stelgidopteryx  ruficollis) 
Barn  Swallow  (Hirundo  rustica) 
Cliff  Swallow  (Petrochelidon  pyrrhonota) 
Purple  Martin  (Progne  subis) 

Gray  Jay  (Perisoreus  canadensis) 
Steller's  Jay  (Cyanocitta  stelleri) 
Scrub  Jay  (Aphelocoma  coerulescens) 
Northern  Raven  (Corvus  corax) 
American  Crow  (Corvus  brachyrhynchos) 
Black-capped  Chickadee  (Parus  atricapillus) 
Mountain  Chickadee  (Parus  gambeli) 
Chestnut-backed  Chickadee  (Parus  rufescens) 
Bushtit  (Psaltriparus  minimus) 
White-breasted  Nuthatch  (Sitta  carolinensis) 
Red-breasted  Nuthatch  (Sitta  canadensis) 
Pygmy  Nuthatch  (Sitla  pygmea) 
Brown  Creeper  (Certhia  familaris) 
Wrentit  (Chamaea  fasciata) 
Dipper  (Cinclus  mexicanus) 
House  Wren  (Troglodytes  aedon) 
Winter  Wren  (Troglodytes  trogladytes) 
Bewick's  Wren  (Thryomanes  bewickii) 
Long-billed  Marsh  Wren  (Cistothorus  palustris) 
American  Robin  (Turdus  migratorius) 
Varied  Thrush  (Ixoreus  naevius) 
Hermit  Thrush  (Catharus  guttata) 
Swainson's  Thrush  (Catharus  ustulata) 
Western  Bluebird  (Sialia  mexicana) 
Townsend's  Solitaire  (Myadestes  townsendi) 
Golden-crowned  Kinglet  (Regulus  satrapa) 


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Appendix  D  Wildlife  (continued) 


177 


Conifer  Habitat 


Other  Habitat 


Key 

Resident  Habitat 

P^Permanent  U=Uses 

S=Summer  0=Optimum 

W=Winter 
M=Migratory 

Relative  Abundance 

A-Abundant 
OCommon 
U=Uncommon 
R=Rare 


Ruby-crowned  Kinglet  (Regulus  calendula) 
Water  Pipit  (Anthus  spinoletta) 
Bohemian  Waxwing  (Bombycilla  garrulus) 
Cedar  Waxwing  (Bombycilla  cedrorum) 
Northern  Shrike  (Lanius  excubitor) 
Starling  (Sturnus  vulgaris) 
Hutton's  Vireo  (Vireo  huttoni) 
Solitary  Vireo  (Vireo  solitarius) 
Warbling  Vireo  (Vireo  gilvus) 

Orange-crowned  Warbler  (Vermivora  celata) 
Nashville  Warbler  (Vermivora  ruficapilla) 
Yellow  Warbler  (Dendroica  petechia) 
Yellow-rumped  Warbler  (Dendroica  coronata) 
Black-throated  Gray  Warbler  (Dendroica  nigrescens) 
Townsend's  Warbler  (Dendroica  townsendi) 
Hermit  Warbler  (Dendroica  occidentalis) 
MacGillivray's  Warbler  (Oporornis  tolmiei) 
Yellowthroat  (Geothlypis  trichas) 
Yellow-breasted  Chat  (Icteria  virens) 
Wilson's  Warbler  (Wilsonia  pusilla) 
House  Sparrow  (Passer  domesticus) 
Western  Meadowlark  (Sturnella  neglecta) 
Yellow-headed  Blackbird 

(Xanthocephalus  xanthocephalus) 
Red-winged  Blackbird  (Agelaius  phoeniceus) 
Northern  Oriole  (Icterus  galbula) 
Brewer's  Blackbird  (Euphagus  cyanocephalus) 
Brown-headed  Cowbird  (Molothrus  ater) 
Western  Tanager  (Piranga  ludoviciana) 
Black-headed  Grosbeak 

(Pheucticus  melanocephalus) 
Lazuli  Bunting  (Passerina  amoena) 
Evening  Grosbeak  (Hesperiphona  vespertina) 
Purple  Finch  (Carpodacus  purpureus) 
House  Finch  (Carpodacus  mexicanus) 
Pine  Siskin(Carduelis  pinus) 
American  Goldfinch  (Carduelis  tristis) 
Lesser  Goldfinch  (Carduelis  psaltria) 
Red  Crossbill  (Loxia  curvirostra) 
Rufous-sided  Towhee  (Pipilo  erythrophthalmus) 
Savannah  Sparrow  (Passerculus  sandwichensis) 
Vesper  Sparrow  (Pooecetes  gramineus) 
Dark-eyed  Junco  (Junco  hyemalis) 
Chipping  Sparrow  (Spizella  passerina) 
White-crowned  Sparrow  (Zonotrichia  leucophrys) 
Golden-crowned  Sparrow  (Zonetrichia  atricapilla) 
Fox  Sparrow  (Passerella  iliaca) 
Lincoln's  Sparrow  (Melospiza  lincolnii) 
Song  Sparrow  (Melospiza  melodia) 


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178 


Appendix  D  Wildlife  (continued) 


Key 


Conifer  Habitat 


Other  Habitat 


Resident 

P^Permanent 
S=Summer 
W=Winter 
M-Migratory 

Relative  Abundance 

A=Abundant 
C=Common 
U=Uncommon 
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Western  Pond  Turtle  (Clemmys  marmorata) 
Western  Fence  Lizard  (Sceloporus  occidentalis) 
Western  Skink  (Eumeces  skiltonianus) 
Southern  Alligator  Lizard 

(Gerrhonotus  multicarinatus) 
Northern  Alligator  Lizard  (Gerrhonotus  coeruleus) 
Rubber  Boa  (Charina  bottae) 
Ringneck  Snake  (Diadophis  punctatus) 
Sharp-tailed  Snake  (Contia  tenuis) 
Western  Yellow-bellied  Racer  (Coluber  constrictor) 
Pacific  Gopher  Snake  (Pituophis  melanoleucus) 
Common  Kingsnake  (Lampropeltis  getulus) 
California  Mountain  Kingsnake  (Lampropeltis  zonata)  P 
Common  Garter  Snake  (Thamnophis  sirtalis) 
Western  Terrestrial  Garter  Snake 

(Thamnophis  elegans) 
Western  Aquatic  Garter  Snake  (Thamnophis  couchi) 
Northwestern  Garter  Snake  (Thamnophis  ordinoides) 
Western  Rattlesnake  (Crotalus  molossus) 


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Northwestern  Salamander  (Ambystoma  gracile) 
Long-toed  Salamander  (Ambystoma  macrodactylum) 
Pacific  Giant  Salamander  (Dicamptodon  ensatus) 
Olympic  Salamander  (Rhyacotriton  olympicus) 
Rough-skinned  Newt  (Taricha  granulosa) 
Dunn's  Salamander  (Plethodon  dunni) 
Western  Red-backed  Salamander 

(Plethodon  vehiculum) 
Oregon  Salamander  (Ensatina  eschscholtzi) 
Clouded  Salamander  (Aneides  ferreus) 
Tailed  Frog  (Ascaphus  truei) 
Western  Toad  (Bufo  boreas) 
Pacific  Tree  Frog  (Hyla  regilla) 
Red-legged  Frog  (Rana  aurora) 
Yellow-legged  Frog  (Rana  boylei) 
Bullfrog  (Rana  catesbeiana) 


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179 


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189 


Glossary  of  Terms 


Absorb  -  To  be  held  within  the  structure  of  a 
substance. 

Acre-foot  -  The  volume  of  water  that  will  cover 
one  acre  to  a  depth  of  one  foot. 

Adsorb  -  To  be  held  on  the  surface  of  a  substance. 

Allowable  Cut  -  The  amount  of  forest  products 
that  may  be  harvested  annually  or  periodically 
from  a  specified  area  over  a  stated  period  in 
accordance  with  the  objectives  of  management. 

Allowable  Cut  Effect  (ACE)  -  The  immediate 
increase  in  today's  allowable  cut  which  is  justified 
by  expected  future  increases  in  yields  due  to 
present  or  proposed  management  treatments. 

Allowable  Cut  Determination  Process  -  A  process 
which  deals  with  the  steps  involved  in  the 
development  and  evaluation  of  alternative  levels  of 
timber  production  for  the  purpose  of  establishing 
an  allowable  cut. 

Ambient  -  Surrounding,  on  all  sides;  for  air,  refers 
to  any  unconfined  portion  of  the  atmosphere. 

Anadromous  Fish  -  Fish  which  migrate  from  the 
sea  to  breed  in  fresh  water.  Their  offspring  return 
to  the  sea. 

Aquifer  -  A  geologic  formation  or  structure  that 
transmits  water  in  sufficient  quantity  to  supply  the 


needs  for  a  water  development;  usually  saturated 
sands,  gravel,  fractures,  and  cavernous  and 
vesicular  rock.  The  term  water-bearing  is 
sometimes  used  synonymously  with  aquifer  when 
a  stratum  furnishes  water  for  a  specific  use. 

Archeological  Resources  -  All  evidences  of  past 
human  occupations  other  than  historical 
documents,  which  can  be  used  to  reconstruct  the 
lifeways  of  past  peoples.  These  include  sites, 
artifacts,  environmental  data  and  all  other  relevant 
information. 

Area  of  Critical  Environmental  Concern  (ACEC)  - 

An  area  within  the  public  lands  where  special 
management  attention  is  required  (when  such 
areas  are  developed  or  used,  or  where  no 
development  is  required)  to  protect  and  prevent 
irreparable  damage  to  important  historic,  cultural, 
or  scenic  values,  fish  and  wildlife  resources  or 
other  natural  systems  or  processes,  or  to  protect 
life  and  safety  from  natural  hazards  (FLPMA  Sec. 
103(a)). 

Aspect  -  The  direction  a  slope  faces. 

Average  Employment  -  The  sum  of  number  of 
employees,  reported  monthly,  divided  by  twelve; 
because  employment  is  reported  for  all  employees 
working  during  any  one  month,  it  is  a  modest 
over-estimate  of  full-time  equivalent  employment. 


190 

Background  -  That  portion  of  an  area  being 
viewed  beyond  the  foreground-middleground  (3  to 
5)  miles  to  a  maximum  of  about  15  miles  from  a 
travel  route,  use  area,  or  other  observer  position. 

Background  Levels  -  Amounts  of  pollutants 
present  from  natural  sources  and  from  human 
disturbances  which  have  reached  equilibrium. 

Basal  Area  -  The  area  of  the  cross-section  of  a 
tree  stem  near  its  base,  generally  at  breast  height 
and  inclusive  of  bark.  It  is  usually  expressed  as 
square  feet  per  acre. 

Bedload  -  The  sediment  that  moves  by  sliding, 
rolling  or  bounding,  on  or  very  near,  the 
streambed. 

Biome  -  The  largest  land  community  unit  (plant 
and  animal)  which  is  convenient  to  recognize. 

Board  Foot  -  A  unit  of  solid  wood,  1-foot  square 
and  1-inch  thick. 

British  Thermal  Unit  (Btu)  -  A  unit  of  heat  equal  to 
252  calories;  quantity  of  heat  needed  to  raise  the 
temperature  of  one  pound  of  water  from  62    F.  to 
63    F. 

Broadcast  Burning  -  Intentional  burning  in  which 
fire  is  intended  to  spread  over  all  of  a  specific 
area.  It  may  or  may  not  qualify  as  prescribed 
burning. 

Bucking  -  Cutting  trees  into  log  lengths. 

Buffer  Strip  -  A  protective  area  adjacent  to  an  area 
requiring  special  attention  or  protection. 

Bureau  Planning  System  -  A  process  used  in  the 
BLM  to  establish  land  use  allocations,  constraints, 
and  objectives  for  various  categories  of  public 
land  use. 

Characteristic  Landscape  -  The  established 
landscape  within  a  physiographic  province.  The 
term  does  not  necessarily  mean  "naturalistic 
character."  It  could  refer  to  farm  lands,  timber 
lands  or  other  landscapes  which  exhibit  both 
physiographic  and  land  use  similarities. 

Clearcutting  -  A  method  of  timber  harvesting  in 
which  all  trees,  merchantable  or  unmerchantable, 
are  cut  from  an  area. 

Commercial  Forest  Land  -  Forest  land  that  is  now 
producing  or  is  capable  of  producing  at  least  20 
cubic  feet  per  acre  per  year  of  commercial 
coniferous  tree  species. 

Commercial  Thinning  -  Partial  cuttings  made  in 
merchantable  stands  (40-70  years  old)  in  order  to 
stimulate  the  growth  of  remaining  trees  and 
increase  total  yield  from  the  stand. 

Community  Income  Effect  -  The  sum  of  direct  and 
indirect  personal  income  generated  by  a  change, 


e.g.,  timber  harvest.  Indirect  personal  income 
results  from  economic  activity  stimulated  in  other 
local  enterprises  by  purchase  of  goods  and 
services,  primarily  of  a  support  nature. 

Constrained  Timber  Production  Base  -  Base 
acreage  managed  for  timber  production  at  a  lesser 
intensity  in  consideration  for  other  resource 
management  objectives,  e.g.,  minimum  harvest 
ages  of  60  to  350  years  for  wildlife  habitat  (see 
Intensive  Timber  Production  Base). 

Contrast  -  The  effect  of  a  striking  difference  in  the 
form,  line,  color  or  texture  of  the  landscape 
features  within  the  area  being  viewed. 

Contrast  Rating  System  -  A  method  of 
determining  the  extent  of  visual  impact  for  an 
existing  or  proposed  activity  that  will  modify  any 
landscape  feature  (land  and  water  form, 
vegetation  and  structures). 

Coos  Bay  Wagon  Road  (CBWR)  Lands  -  Public 
lands  granted  to  the  Southern  Oregon  Company 
and  subsequently  reconveyed  to  the  United 
States. 

Critical  Habitat  -  That  habitat  considered  by  the 
Secretary  of  the  Interior  to  be  necessary  to  the 
normal  needs  or  survival  and  recovery  of  listed 
Threatened  or  Endangered  Species.  It  may  also 
include  habitat  not  currently  occupied  into  which 
a  listed  species  could  expand. 

Cull  -  A  tree  or  log  which  is  rejected  because  it 
does  not  meet  certain  specifications. 

Cultural  Resources  -  Those  fragile  and 
nonrenewable  remains  of  human  activity, 
occupation,  or  endeavor,  reflected  in  districts, 
sites,  structures,  buildings,  objects,  artifacts, 
ruins,  works  of  art,  architecture,  and  natural 
features,  that  were  of  importance  in  human  events. 
These  resources  consist  of  (1)  physical  remains, 
(2)  areas  where  significant  human  events 
occurred—even  though  evidence  of  the  event  no 
longer  remains,  and  (3)  the  environment 
immediately  surrounding  the  actual  resource. 
Cultural  resources,  including  both  prehistoric  and 
historic  remains,  represent  a  part  of  the 
continuum  of  events  from  the  earliest  evidences  of 
man  to  the  present  day. 

Debris  Avalanche  -  Fast  moving  failures  of 
shallow,  generally  cohesionless  soils  on  steep 
slopes  over  an  impermeable  failure  surface. 

Debris  Torrent  -  A  very  fluid  mass  of  soil,  rock  and 
vegetative  debris  that  moves  rapidly  down  steep, 
narrow  stream  channels. 

Discharge  -  Rate  of  flow  of  a  fluid,  the  volume  of 
fluid  passing  a  point  per  unit  of  time,  commonly 
expressed  as  cubic  feet  per  second  (cfs),  million 
gallons  per  day,  gallons  per  minute,  or  cubic 
meters  per  second. 


191 


Distance  Zone  -  The  area  that  can  be  seen  as 
foreground-middleground,  background,  or 
seldom-seen. 

Ecosystem  -  An  ecological  unit  consisting  of  both 
living  and  nonliving  components  which  interact  to 
produce  a  natural,  stable  system. 

Environmental  Assessment  (EA)  -  A  systematic 
environmental  analysis  of  site-specific  BLM 
activities  used  to  determine  whether  such 
activities  have  a  significant  effect  on  the  quality  of 
the  human  environment  and  whether  a  formal 
environmental  impact  statement  is  required. 

Environmental  Impact  Statement  (EIS)  -  A  formal 
document  to  be  filed  with  the  Environmental 
Protection  Agency  that  considers  significant 
environmental  impacts  expected  from 
implementation  of  a  major  federal  action. 

Erosion  (soil)  -  Removal  of  soil  from  its  place  of 
origin  to  a  point  of  deposition  other  than  a  stream 
channel. 

Even  Flow  -  Maintaining  a  relatively  constant 
undiminishing  supply  of  timber  from  year  to  year 
for  the  planning  cycle. 

Fauna  -  All  the  animals  in  a  given  area. 

Final  Harvest  Cut  -  Constitutes  removal  of  a 
mature  stand,  either  through  clearcutting,  the  final 
stage  of  a  shelterwood  regime,  or  overstory 
removal. 

Flora  -  All  the  plants  in  a  given  area. 

Forbs  -  Herbaceous  plants;  most  often  used 
pertaining  to  herbaceous  plants  eaten  by  wildlife. 

Foreground-middleground  -  The  area  visible  from 
a  travel  route,  use  area,  or  other  observer  position 
to  a  distance  not  exceeding  five  miles.  The  outer 
boundary  of  this  zone  is  defined  as  the  point 
where  the  texture  and  form  of  individual  plants  are 
no  longer  apparent  in  the  landscape.  Vegetation  is 
apparent  only  in  patterns  or  outline. 

Forest  Canopy  -  The  more  or  less  continuous 
cover  of  branches  and  foliage  formed  collectively 
by  the  crowns  of  adjacent  trees  and  other  woody 
growth. 

Forest  Land  -  Land  that  is  now,  or  is  capable  of 
becoming,  at  least  10  percent  stocked  with  forest 
trees  and  that  has  not  been  developed  for 
nontimber  use. 

Forest  Management  Program  -  Includes  timber 
activity  plan  and  all  forest  resource  related 
program  activity  plans. 

Forest  Type  Island  -  An  aggregation  of  trees 
occupying  a  specific  area  and  sufficiently  uniform 
in  composition,  age,  arrangement  and  condition  to 


be  distinguishable  from  vegetation  on  adjoining 
areas. 

Groundwater  -  Subsurface  water  in  the  zone  of 
saturation. 

Growing  Stock  -  The  amount  of  standing,  green 
timber  retained  to  produce  forest  products;  also 
known  as  forest  capital. 

Habitat  -  The  environment  in  which  an  organism 
occurs. 

High-lead  Logging  -  A  cable  yarding  system  in 
which  lead  blocks  are  hung  on  a  spar  or  tower  to 
provide  lift  to  the  front  end  of  logs  giving  partial 
suspension. 

Historic  Resources  -  All  evidences  of  human 
activity  that  date  from  historic  (i.e.,  recorded 
history)  periods.  These  resources  include 
documentary  data  (i.e.,  written  records,  archival 
material,  photographs,  maps,  etc.),  sites,  artifacts, 
environmental  data,  and  all  other  relevant 
information.  Also  included  are  locations  where 
documented  historical  events  took  place,  even 
though  no  physical  evidence  of  the  events  remain 
other  than  the  setting.  Historic  resources  are 
cultural  resources  and  may  be  considered 
archeological  resources  when  archeological  work 
is  involved  in  their  identification  and 
interpretation. 

Igneous  Rock  -  Rock  formed  from  the  cooling  and 
solidification  of  molten  rock. 

Infiltration  (soil)  -  Downward  entry  of  water  into 
the  soil. 

Intensive  Forest  Management  Lands  -  All 

commercial  forest  land  that  is  part  of  the  timber 
production  base  for  allowable  cut  calculation  in 
the  Douglas  and  South  Umpqua  Sustained  Yield 
Units. 

Intensive  Timber  Production  Base  -  Base  acreage 
intensively  managed  for  timber  production  using  a 
50-year  minimum  harvest  age  in  the  allowable  cut 
computation. 

Intermediate  Cuttings  -  Any  removal  of 
merchantable  trees  from  a  stand  prior  to  the  final 
harvest  cutting,  i.e.,  commercial  thinning, 
sanitation/salvage,  or  shelterwood  regeneration 
cuttings. 

Landing  -  Any  place  on  or  adjacent  to  the  logging 
site  where  logs  are  assembled  for  further 
transport. 

Landscape  Features  -  The  land  and  water  form, 
vegetation,  and  structures  which  compose  the 
characteristic  landscape. 


192 


Leach  -  Usually  refers  to  the  movement  of 
chemicals  through  soil  by  water;  may  also  refer  to 
movement  of  herbicides  out  of  leaves,  stems  or 
roots  into  the  air  or  soil. 

Log  Flows  -  Destinations  of  harvested  timber  by 
origin.  Origins  used  herein  are  management  units 
and  counties  or  county  groupings;  destinations 
are  communities,  counties  or  groupings  of 
counties  within  which  the  primary  processing  of 
timber  takes  place. 

Lumber  and  Wood  Products,  except  Furniture  - 

Defined  by  the  Office  of  Management  and  Budget 
and  the  Standard  Industrial  Classification  Manual 
as  Major  Group  #24,  which  includes  logging 
contractors  engaged  in  cutting  timber  and 
pulpwoods;  merchant  sawmills,  lath  mills,  shingle 
mills,  planing  mills,  plywood  mills,  and  veneer 
mills  engaged  in  producing  lumber  and  wood 
basic  materials;  and  establishments  engaged  in 
manufacturing  finished  articles  made  entirely  or 
mainly  of  wood  or  wood  substitutes.  Certain  types 
of  establishments  producing  wood  products  are 
classified  elsewhere,  e.g.,  furniture  and  office  and 
store  fixtures  are  classified  in  Major  Group  #25. 

Management  Framework  Plan  (MFP)  -  Land  use 
plan  for  public  lands  which  provides  a  set  of  goals, 
objectives,  and  constraints  for  a  specific  planning 
area  to  guide  the  development  of  detailed  plans 
for  the  management  of  each  resource. 

Mass  Failure  -  See  Mass  Movement. 

Mass  Movement  -  Downslope  movement  of  soil 
and  rock  caused  by  gravity;  may  be  slow  (creep) 
or  rapid  (landslide,  debris  avalanche). 

Metamorphic  Rock  -  Rock  formed  from 
preexisting  rocks  but  changed  by  heat  and/or 
pressure  to  rock  with  new  physical,  chemical  and 
mineralogical  properties. 

Microclimate  -  The  climatic  condition  of  a  small 
area  modified  from  the  general  climatic  conditions 
by  local  differences  in  elevation  or  exposure. 

Minimum  Harvest  Age  -  The  lowest  age  of  a  stand 
to  be  scheduled  for  final  harvest. 

Mixing  Height  -  The  height  above  the  ground 
through  which  vertical  mixing  of  air  is  relatively 
vigorous. 

Mortality  Salvage  -  See  sanitation/salvage  cutting. 

Multiple  Use  -  Management  of  the  public  lands 
and  their  various  resource  values  so  that  they  are 
utilized  in  the  combination  that  will  best  meet  the 
present  and  future  needs  of  the  American  people. 

National  Natural  Landmark  -  Areas  designated  by 
the  Secretary  of  Interior  which  contain 
representative  examples  of  the  nation's  natural 
history,  including  terrestrial  communities,  aquatic 


communities,  landforms,  geological  features  or 
habitats  of  native  plant  and  animal  species, 
possessing  national  significance  in  illustrating  or 
interpreting  the  nation's  natural  heritage. 

National  Register  of  Historic  Places  -  The  official 
list,  established  by  the  Historic  Preservation  Act  of 
1966,  of  the  Nation's  cultural  resources  worthy  of 
preservation.  The  Register  lists  archeological, 
historic,  and  architectural  properties  (i.e.,  districts, 
sites,  buildings,  structures,  and  objects) 
nominated  for  their  local,  State,  or  national 
significance  by  State  and/or  Federal  agencies  and 
approved  by  the  National  Register  staff.  The 
Register  is  maintained  by  the  National  Park 
Service. 

Natural  Levels  -  Amount  of  pollutants  present 
from  natural  sources  without  human  disturbances 
which  have  reached  equilibrium. 

Non-commercial  Forest  Land  -  Land  which  is  not 
capable  of  yielding  at  least  20  cubic  feet  of  wood 
per  acre  per  year  from  commercial  species,  or 
land  which  is  capable  of  producing  only  non- 
commercial tree  species. 

Non-degradation  Policy  -  Use  of  the  highest  and 
best  practicable  treatment  and/or  control  of 
wastes,  activities  and  flows  to  maintain  water 
quality  at  the  highest  possible  levels. 

Non-forest  Land  -  Land  that  has  been  developed 
for  non-timber  uses  or  land  that  is  incapable  of 
being  10  percent  stocked  with  forest  trees. 

Non-point  Source  Pollution  -  Pollution  caused  by 
the  introduction  of  materials  from  diffuse  sources 
(e.g.,  sediment,  nutrients),  or  from  a  natural  or 
manmade  alteration  in  the  stream  system. 

O&C  Lands  -  Public  lands  granted  to  the  Oregon 
and  California  Railroad  Company  and 
subsequently  revested  to  the  United  States. 

Old  growth  -  A  forest  containing  many  large  trees 
with  large  snags  and  numerous  large,  down  logs. 
There  is  a  multi-layered  canopy  of  several  species. 
Some  of  the  older  trees  are  beginning  to  show 
signs  of  decadence.  Small  openings  are  scattered 
throughout  the  forest.  In  western  Oregon,  forests 
begin  to  have  old  growth  characteristics  at  about 
200  years. 

Old-Growth  Dependent  -  An  animal  species  so 
adapted  that  it  can  exist  only  in  old-growth 
forests. 

Operations  Inventory  -  An  intensive  forest 
inventory  which  provides  managers  with 
information  showing  the  location,  acreage, 
silvicultural  needs,  and  mortality-salvage  or 
thinning  needs  within  each  section  of  public  land. 


193 


Oregon  Endangered  Species  Task  Force  -  An 

Interagency  task  force  represented  by  ODF&W, 
USFS,  BLM,  USF&WS,  and  Oregon  State 
University,  organized  in  1973,  to  established 
habitat  management  guidelines  for  Oregon 
Endangered  Wildlife  Species. 

Outstanding  Natural  Areas  -  Areas  of  outstanding 
scenic  splendor,  natural  wonder  or  scientific 
importance  that  merit  preservation  in  their  natural 
condition.  The  preservation  of  these  resources  in 
their  natural  condition  is  the  primary  management 
objective.  Access  roads,  parking  areas  and  public 
use  facilities  are  normally  located  on  the  fringe  of 
the  area.  The  public  is  encouraged  to  walk  into  the 
area  for  recreation  purposes  wherever  feasible. 

Paleontology  -  A  science  dealing  with  the  life  of 
past  geological  periods  as  known  from  fossil 
remains. 

Partial  Cutting  -  Tree  removal  other  than  by 
clearcutting. 

Particulates  -  Finely  divided  solid  or  liquid 
particles  in  the  air  or  in  an  emission;  includes 
dust,  smoke  fumes,  mist,  spray  and  fog. 

Peak  Flow  -  The  highest  amount  of  stream  or  river 
flow  occurring  in  a  year  or  for  a  single  storm 
event. 

Perched  Water  Table  -  The  surface  of  a  local  zone 
of  saturation  held  above  the  main  body  of 
groundwater  by  an  an  impermeable  layer  or 
stratum,  usually  clay,  and  separated  by  the  main 
body  of  ground  water  by  an  unsaturated  zone. 

Permeability  (soil)  -  The  quality  of  a  soil  horizon 
that  enables  water  or  air  to  move  through  it;  may 
be  limited  by  the  presence  of  one  nearly 
impermeable  horizon  even  though  the  others  are 
permeable. 

Personal  Income  -  The  income  received  by  all 
individuals  in  the  economy  from  all  sources;  made 
up  of  wage  and  salary  disbursements,  proprietors 
income,  rental  income  of  persons,  dividends, 
personal  interest  income,  and  the  difference 
between  transfer  payments  and  personal 
contributions  for  social  insurance. 

Phytoplankton  -  Suspended,  floating  or  weakly 
swimming  microscopic  aquatic  plants. 

Plankton  -  Organisms  of  relatively  small  size, 
mostly  microscopic,  that  either  have  relatively 
small  powers  of  locomotion  or  drift  in  the  water 
subject  to  the  action  of  waves  and  currents. 

Plant  Community  -  An  association  of  plants  of 
various  species  found  growing  together  in 
different  areas  with  similar  site  characteristics. 

Plantation  Release  -  Any  action  taken  on  an 
established  commercial  timber  stand  to  control 


stand  composition  and  promote  dominance 
and/or  growth  of  suitable  tree  species.  Treatments 
may  include  mechanical  or  manual  slashing  of 
undesirable  brush  and  tree  species,  herbicide, 
biological,  or  a  combination  of  methods.  Forest 
fertilization  is  not  considered  a  release  treatment. 

Plantation  Stocking  Maintenance  -  Any  vegetation 
management  action  taken  on  an  unestablished 
stand  to  promote  the  survival  and  establishment  of 
suitable  trees.  Treatments  may  include  using 
biological,  mechanical,  or  manual  weeding, 
mulching,  herbicide  or  a  combination  of  methods. 

Precommercial  Thinning  -  Partial  cuttings  made  in 
immature  stands  (10-25  years)  in  order  to 
stimulate  the  growth  of  remaining  trees  by  making 
available  increased  soil  moisture,  thereby 
increasing  total  yield  from  the  stand. 

Prehistoric  -  Pertaining  to  that  period  of  time 
before  written  history. 

Progeny  Site  -  A  test  area  for  evaluating  parent 
seed  trees  by  comparing  the  performance  of  their 
offspring  seedlings. 

Protection  -  Any  action  taken  to  protect  suitable 
trees  from  adverse  elements  such  as  weather, 
animals,  insects,  and  disease.  Treatments  include 
all  practices  which  increase  chances  for  survival 
and  normal  growth  of  desired  tree  species. 

Public  Lands  -  Any  land  and  interest  in  land 
owned  by  the  United  States  within  the  several 
States  and  administered  by  the  Secretary  of  the 
Interior  through  the  Bureau  of  Land  Management. 
May  include  public  domain,  O&C  or  acquired 
lands  in  any  combination. 

Public  Domain  Lands  -  Original  holdings  of  the 
United  States  never  granted  or  conveyed  to  other 
jurisdictions. 

Recharge  -  Process  by  which  water  is  added  to  the 
zone  of  saturation,  as  in  recharge  of  an  aquifer. 

Recreation  Experience  Opportunity  -  The 

opportunity  for  a  person  to  realize  predictable 
psychological  and  physiological  outcomes  from 
engaging  in  a  specific  recreation  activity  within  a 
specific  setting. 

Recreation  Opportunity  Setting  -  Combination  of 
physical,  biological,  social,  and  managerial 
attributes  present  on  a  particular  land  area  which 
influences  the  experience  obtained  by  engaging  in 
a  specific  recreation  activity. 

Reforestation  -  Reestablishment  of  a  tree  crop  on 
forest  land. 

Regeneration  -  The  renewal  of  a  commercial  tree 
crop,  whether  by  natural  or  artificial  means;  also, 
the  young  crop  itself. 


194 

Regeneration  Period  -  The  time  it  takes  for  a  new 
commercial  timber  stand  to  become  stocked 
following  the  date  of  a  timber  sale. 

Regulated  Forest  -  A  forest  comprises  a  desired 
(usually  even)  distribution  of  age  classes  or  tree 
sizes,  when  the  growth  equals  the  cut  (at  the 
highest  level  sustainable)  and  when  the  level  of 
growing  stock  remains  relatively  constant. 

Research  Natural  Areas  -  Areas  established  and 
maintained  for  research  and  education.  The 
general  public  may  be  excluded  or  restricted 
where  necessary  to  protect  studies  or  preserve 
research  natural  areas.  Lands  may  have:  (1) 
typical  or  unusual  faunistic  or  floristic  types, 
associations,  or  other  biotic  phenomena,  or  (2) 
characteristic  or  outstanding  geologic,  pedologic 
or  aquatic  features  or  processes. 

Riparian  Habitat  (Area  or  Zone)  -  Those  terrestrial 
areas  where  the  vegetation  complex  and 
microclimate  conditions  are  products  of  the 
combined  presence  and  influence  of  perennial 
and/or  intermittent  water,  associated  high  water 
tables  and  soils  which  exhibit  some  wetness 
characteristics. 

Runoff  -  That  part  of  precipitation,  as  well  as  any 
other  flow  contributions,  which  appears  in  surface 
streams,  either  perennial  or  intermittent. 

Sanitation/Salvage  Cutting  -  Removal  of  individual 
trees  killed  or  injured  by  fire,  insects,  disease,  etc., 
and  the  removal  of  those  trees  likely  to  die  prior  to 
final  harvest  cut  so  as  to  utilize  merchantable 
material. 

Sawlog  -  A  log  considered  suitable  in  size  and 
quality  for  producing  sawn  timber. 

Scenic  Quality  -  The  degree  (high,  moderate,  and 
low)  of  visual  harmony  and  variety  within  a 
landscape  as  compared  to  other  units  within  the 
physiographic  region. 

Scribner  Log  Rule  -  A  log  rule  constructed  from 
diagrams  which  shows  the  number  of  1-inch 
boards  which  can  be  drawn  in  a  circle 
representing  the  small  end  of  a  log;  assumes  a 
1/4-inch  saw  kerf,  makes  a  liberal  allowance  for 
slabs,  and  disregards  taper. 

Sediment  Yield  -  The  quantity  of  sediment, 
measured  in  dry  weight  or  by  volume,  transported 
in  water  flowing  through  a  stream  cross-section  in 
a  given  time.  Consists  of  both  suspended 
sediment  and  bedload. 

Sedimentary  Rock  -  A  rock  formed  from  materials 
deposited  from  suspension  or  precipitated  from 
solution  and  usually  more  or  less  consolidated; 
e.g.,  sandstone,  shale,  limestone  and 
conglomerates. 


Seldom  Seen  -  Portions  of  the  landscape  which 
are  generally  not  visible  from  observer  positions, 
or  areas  which  are  visible  beyond  15  miles  from 
those  positions. 

Sensitive  Species  -  Species  not  yet  officially  listed 
but  which  are  undergoing  a  status  review  or  are 
proposed  for  listing  according  to  Federal  Register 
notices  published  by  the  Secretary  of  the  Interior 
or  Secretary  of  Commerce,  or  according  to 
comparable  State  documents  published  by  State 
officials.  (Reference  Instruction  Memo  W.O. 
80-722.) 

Sensitivity  Level(s)  -  The  degree  (high,  medium, 
low)  of  user  interest  in  scenic  quality  and  concern 
about  possible  changes  in  the  landscape  features 
of  an  area.  The  two  criteria  for  determining 
sensitivity  levels  are  user  volumes  and  user 
attitudes. 

Serai  Stage  -  The  relatively  transitory  communities 
within  a  sere. 

Sere  -  The  whole  series  of  communities  which 
develop  in  a  given  situation. 

Shelterwood  Cutting  -  A  series  of  partial  cuttings 
designed  to  establish  a  new  crop  of  trees  under 
the  protection  of  the  old. 

Silviculture  -  The  art  of  producing  and  tending  a 
forest. 

Siphon  -  A  pipe  which  uses  atmospheric  pressure 
to  transfer  water  from  one  point  to  another  against 
gravity. 

Site  Class  -  A  measure  of  the  relative  productive 
capacity  of  an  area  for  timber  or  other  vegetation. 

Site  Preparation  -  Any  action  taken  in  conjunction 
with  a  reforestation  effort  (natural  or  artificial)  to 
create  an  environment  which  is  favorable  for 
survival  of  suitable  trees  during  the  first  growing 
season.  This  environment  can  be  created  by 
altering  ground  cover,  soil  or  microsite  conditions, 
using  biological,  mechanical,  or  manual  clearing, 
prescribed  burning,  herbicide  or  a  combination  of 
methods. 

Slash  -  The  branches,  bark,  tops,  cull  logs,  and 
broken  or  uprooted  trees  left  on  the  ground  after 
logging  has  been  completed. 

Slump  -  Rotational  failure  of  a  discrete  block  of 
soil  on  a  failure  plane  that  is  curved  from  top  to 
bottom  and  from  side  to  side.  The  block  rotates 
downward  and  outward  along  this  failure  plane 
while  remaining  more  or  less  intact. 

Smolt  -  A  young  salmon  or  trout  that  is  migrating 
from  freshwater  to  the  ocean. 

Snag  -  A  standing  dead  tree  from  which  the  leaves 
and  most  of  the  limbs  have  fallen. 


195 


Soil  -  The  unconsolidated  mineral  and  organic 
material  on  the  immediate  surface  of  the  earth  that 
serves  as  a  natural  medium  for  the  growth  of  land 
plants. 

Soil  Mapping  Unit  -  A  combination  of  soils,  or 
miscellaneous  land  type  or  types  that  can  be 
shown  at  the  scale  of  mapping  for  the  defined 
purposes  of  the  survey;  the  basis  for  the 
delineations  of  a  soil  survey  map. 

Soil  Productivity  -  The  capacity  of  a  soil  in  its 
normal  environment  to  produce  a  specified  plant 
or  sequence  of  plants  under  a  specified  system  of 
management. 

Standard  Industrial  Classification  (SIC)  -  An 

industrial  classification  system  as  defined  by  the 
Office  of  Management  and  Budget;  defines 
industries  in  accordance  with  the  composition  and 
structure  of  the  economy  and  covers  the  entire 
field  of  economic  activity.  Refer  to  lumber  and 
wood  products  for  an  explanation  of  SIC  24. 

State  Historic  Preservation  Officer  (SHPO)  -  The 

official  within  each  State,  authorized  by  the  State 
at  the  request  of  the  Secretary  of  the  Interior,  to 
act  as  a  liaison  for  purposes  of  implementing  the 
National  Historic  Preservation  Act  of  1966. 

Stream  Order  -  A  system  of  stream  classification. 
Each  small  unbranched  tributary  is  a  first  order 
stream.  Two  first  order  streams  join  to  make  a 
second  order  stream.  A  third  order  stream  has 
only  first  and  second  order  tributaries,  and  so 
forth. 

Subsurface  Flow  -  Horizontal  movement  of  water 
through  the  soil  profile. 

Succession  -  The  orderly  process  of  plant 
community  change.  Process  by  which  one  plant 
community  will  succeed  another  over  time  given 
the  same  climatic  conditions. 

Surplus  Inventory  -  A  temporary  (1-3  decades) 
excess  of  growing  stock  over  and  above  that 
which  is  necessary  to  sustain  the  even  flow  level. 

Survival  Cover  -  Cover  required  by  animals  to 
mitigate  effects  of  a  period  of  severe  weather  that 
cannot  be  met  by  thermal  cover.  The  objective  of 
survival  cover  is  to  provide  a  forest  stand  structure 
which  will  provide  shade  during  times  of  high 
temperatures  and  intercept  snow  during  severe 
storms  and  provide  significant  quantities  of  forage 
in  the  same  stand.  Stand  closure  should  be  at 
least  75  percent  or  more. 

Suspended  Sediment  -  Sediment  suspended  in  a 
fluid  by  the  upward  components  of  turbulent 
currents  or  by  colloidal  suspension. 

Sustained  Yield  -  The  yield  that  a  forest  can 
produce  continuously  at  a  given  intensity  of 
management. 


Teratogenicity  -  Ability  of  a  substance  to  cause 
abnormal  development  of  a  fetus. 

Texture  (soil)  -  The  relative  proportion  of  sand,  silt 
and  clay  (expressed  as  percentages)  in  a  soil; 
grouped  into  standard  classes  and  subclasses  in 
the  USDA  Soil  Survey  Manual. 

Thermal  Cover  -  Cover  used  by  animals  to 
ameliorate  effects  of  weather.  For  elk,  a  stand  of 
conifer  trees  which  are  40  feet  or  more  tall  with  an 
average  crown  closure  of  70  percent  or  more.  For 
deer,  cover  may  include  saplings,  shrubs  or  trees 
at  least  5  feet  tall  with  75  percent  crown  closure. 

Timber  Lands  -  See  Forest  Land. 

Timber  Preservation  Area  -  An  area  withdrawn 
from  mineral  entry  and  the  timber  base  to  protect 
the  scientific  and  educational  values  of  timber 
resources. 

Timber  Production  Base  -  Acres  included  in  the 
calculation  of  the  allowable  cut  (see  Intensive 
Forest  Management  Lands). 

Timber  Production  Capability  Classification 
(TPCC)  -  A  classification  system  that  identifies  the 
commercial  forest  and  base  capable  of  producing 
timber  on  a  sustained  yield  basis. 

True  Fir  -  A  member  of  the  genus  Abies,  e.g., 
white  fir  (Abies  concolor).  Douglas-fir 
(Pseudotsuga  menziesii)  is  not  a  true  fir. 

Understory  Species  -  Shade-tolerant  plant  species 
which  characteristically  grow  beneath  the  forest 
canopy;  e.g.,  blackberry  and  rhododendron. 

Unit  Resource  Analysis  (URA)  -  A  BLM  planning 
document  which  contains  a  comprehensive 
inventory  and  analysis  of  the  resources  within  a 
specified  geographic  area  and  an  analysis  of  their 
potential  for  development. 

Visitor-day  -  Twelve  visitor-hours,  which  may  be 
aggregated  continuously,  intermittently  or 
simultaneously  by  one  or  more  persons.  Visitor- 
days  may  occur  either  as  recreation  visitor-days  or 
as  non-recreation  visitor-days. 

Visual  Resource  Basic  Elements  -  The  four  major 
elements  (form,  line,  color,  texture)  which 
determine  how  the  character  of  a  landscape  is 
perceived. 

Visual  Resources  -  The  land,  water,  vegetation, 
animals  and  other  features  that  are  visible  on  all 
public  lands  (scenic  values). 

Visual  Resource  Management  (VRM)  -  The 

planning,  design  and  implementation  of 
management  objectives  to  provide  acceptable 
levels  of  visual  impacts. 


196 

Visual  Resource  Management  Classes  -  The 

degree  of  alteration  that  is  acceptable  within  the 
characteristic  landscape.  Based  upon  the  physical 
and  sociological  characteristics  of  any  given 
homogeneous  area  and  serves  as  a  management 
objective  to  mitigate  or  avoid  adverse  visual 
impacts.  Class  I  provides  the  highest  level  of 
protection  for  scenic  values,  and  Class  IV  the 
lowest  level. 

Volatilize  -  To  evaporate;  to  change  from  a  liquid 
to  a  gas. 

Water  Quality  -  The  combined  physical,  chemical 
and  biological  characteristics  of  water  bodies. 

Watershed  -  The  area  drained  by  a  given  stream. 

Wetland  or  Wetland  Habitat  -  Permanently  wet  or 
intermittently  flooded  areas  where  the  water  table 
(fresh,  saline,  or  brackish)  is  at,  near,  or  above  the 
soil  surface  for  extended  intervals,  where  hydric 
wet  soil  conditions  are  normally  exhibited,  and 
where  depths  generally  do  not  exceed  two  meters. 
Vegetation  generally  consists  of  emergent  water- 
loving  forms  (hydrophytes)  which  require  at  least 
a  periodically  saturated  soil  condition  for  growth 
and  reproduction.  In  certain  instances,  vegetation 
may  be  completely  lacking. 

Wildlife  Tree  -  A  live  tree  remaining  after  timber 
harvest  that  can  become  a  snag  for  cavity  dwelling 
wildlife. 

Yarding  -  The  act  or  process  of  conveying  logs  to 
a  landing. 


197 


References  Cited 


Adams,  Darius  M. 

1977.  Effects  of  National  Forest  Timber  Harvest  on 
Softwood  Stumpage,  Lumber,  and  Plywood 
Markets:  An  Econometric  Analysis.  For.  Res.  Lab. 
Res.  Bull.  15,  Oregon  State  University,  Feb.  1977. 

and  Richard  W.  Haynes 


1980.  The  1980  Softwood  Timber  Assessment 
Market  Model:  Structure,  Projections,  and  Policy 
Simulations.  Forest  Science  Monograph  22, 
Supplement  to  Forest  Science,  Vol.  26  No.  3. 

Richard  W.  Haynes,  and  David  A.  Darr 

1977.  A  Welfare  Analysis  of  Long-Term  Forest 
Products  Price  Stablization.  American  Journal  of 
Agricultural  Economics,  Vol.  59,  No.  4,  Nov.  1977. 

Baker,  Arthur 

1982.  Personal  communication.  U.S. 
Environmental  Protection  Agency.  Seattle, 
Washington. 

Beuter,  John  H.,  and  Jeffery  K.  Handy 

1974.  Research  Paper  23.  Forestry  Research 
Laboratory,  School  of  Forestry,  Oregon  State 
University,  Corvallis,  Oreg. 

Beuter,  John  H.,  K.  Norman  Johnson,  and  H.  Lynn 
Scheurman 

1976.  Timber  for  Oregon's  Tomorrow:  An  Analysis 
of  Reasonably  Possible  Occurrences.  Research 
Bulletin  19,  Forest  Research  Lab,  Oregon  State 
University,  Corvallis,  Oreg. 


Brown,  George  W.  and  J.T.  Krygier 

1967.  Changing  Water  Temperatures  in  Small 
Mountain  Streams.  In:  Gibbons,  D.R.  and  E.O. 
Salo,  1973.  J.  Soil  and  Water  Conserv.  22(6):  242- 
244. 


1970.  Effects  of  Clearcutting  on  Stream 
Temperature.  Water  Resour.  Res.  6(4):  1133-1139. 
In:  Gibbons,  D.R.  and  E.O.  Salo.  1973.  An 
Annotated  Bibliography  of  the  Effects  of  Logging 
on  Fish  of  the  Western  United  States  and  Canada. 
USDA  For.  Serv.  Gen.  Tech.  Rep.  PNW-10.  Pac. 
Northwest  For.  and  Range  Exp.  Stn.,  Portland, 
Oreg. 


1971.  Clearcut  Logging  and  Sediment  Production 
in  the  Oregon  Coast  Range.  Water  Resources 
Research,  National  Symposium  on  Watersheds  in 
Transition,  Am.  Water  Resour.  Assoc.  Proa,  pp. 
1189-1199,  Urbana,  III.  In:  EPA  1973.  Methods  for 
Identifying  and  Evaluating  the  Nature  and  Extent 
of  Non-point  Sources  of  Pollutants.  EPA, 
Washington,  D.C. 

Bruner,  William  E.  and  Perry  R.  Hagenstein 

1981.  Alternative  Forest  Policies  for  the  Pacific 
Northwest.  Study  Module  V,  Forest  Policy  Project, 
Washington  State  University,  Pullman, 
Washington. 


198 


Bunnell,  F.L.  and  D.S.  Eastman 

1976.  Effects  of  Forest  Management  Practices  of 
Wildlife  in  the  Forests  of  British  Columbia.  In:  Int. 
Union  of  Forest  Res.  Organizations,  16th 
Congress,  Vol.1,  pp.  631-689,  Oslo,  Norway. 

Burden,  Patrick  L. 

1977.  The  Effect  of  Declining  Timber  Supplies  and 
Productivity  Increases  in  the  Forest  Products 
Industries  upon  Employment  in  Douglas  County, 
Oregon.  M.S.  Thesis  Dept.  of  Geography,  Oregon 
State  University,  Corvallis,  Oreg. 

Burroughs,  E.R.,  Jr.,  and  B.R.  Thomas 

1977.  Declining  Root  Strength  in  Douglas-fir  after 
Felling  as  a  Factor  in  Slope  Stability.  USDA  For. 
Serv.  Res.  Pap.  INT-190,  27p.  Intermt.  For.  and 
Range  Exp.  Stn.,  Ogden,  Utah. 

Cameron,  John  J.  and  John  W.  Anderson 

1977.  Results  of  the  Stream  Monitoring  Program 
Conducted  During  FY  1977.  Herbicide  Spray 
Project,  Coos  Bay  District.  USDI,  BLM,  Coos  Bay, 
Oregon. 

Chilcote,  William  W.,  G.P.  Juday,  R.W.  Fonda,  J.O. 
Sawyer  and  A.M.  Wiedemann 

1976.  A  Survey  of  the  Potential  Natural  Landmarks, 
Biotic  Themes,  of  the  North  Pacific  Border  Region. 
A  Report  prepared  for  USDI,  National  Park 
Service. 

Christener,  Jere 

1981.  Changes  in  Peak  Streamflows  from  Managed 
Areas  of  the  Willamette  National  Forest.  USDA 
Forest  Service,  Pacific  Northwest  Region, 
Willamette  National  Forest,  Eugene,  Oreg. 

Clutter,  Jerome  and  Tommy  R.  Dell 

1978.  Expected  Yields  of  Pine  Plantations  on 
Prepared  Sites,  pp.  111-122.  In:  T.  Tippen  (ed.), 
Proceedings:  A  Symposium  on  Principles  of 
Maintaining  Productivity  on  Prepared  Sites, 
Mississippi  State  University,  March  21,  22,  1978. 
USDA  For.  Serv.,  Southern  For.  Exp.  Stn.,  New 
Orleans,  LA. 

Cromack,  K.,  Jr.,  F.J.  Swanson  and  C.  C.  Grier 

1979.  A  Comparison  of  Harvesting  Methods  and 
Their  Impact  on  Soils  and  Environment  in  the 
Pacific  Northwest.  Forest  Soils  and  Land  Use, 
Proc.  5th  N.  Amer.  Forest  Soils  Conf.  Aug.  6-9, 
1978,  USDA-FS. 

Coos-Curry-Douglas  Economic  Improvement 
Association 

1978,  1979.  Comprehensive  Economic 
Development  Strategy.  G.  Anthony  Kuhn, 
Executive  Director,  Roseburg,  Oreg. 


Crouch,  G.L. 

1974.  Interaction  of  Deer  and  Forest  Succession 
on  Clearcuttings  in  the  Coast  Range  of  Oregon.  In: 
Black,  H.C.  (ed.).  1974.  Wildlife  and  Forest  * 
Management  in  the  Pacific  Northwest,  pp.  133-138. 
School  of  Forestry,  Oregon  State  University, 
Corvallis,  Oreg. 

DeCalesta,  David  S.  and  Gary  Witmer 

1980.  "The  Relationship  of  Stand  Development  to 
Habitat  Requirements  of  Elk  in  the  Douglas-fir 
Region  of  the  Coast  Range  of  Oregon".  Final 
Report,  FS-PNW-Grant  No.  18.  Department  of 
Fisheries  and  Wildlife,  Oregon  State  University, 
Corvallis,  Oreg. 

Dost,  Frank  N. 

1983.  An  Analysis  of  Human  Health  Hazards 
Associated  with  Some  Herbicides  Used  in 
Forestry.  Report  prepared  for  USDI,  BLM,  Oregon 
State  Office,  Portland,  Oreg. 

Douglas  County  Oregon 

1980.  Douglas  County  Economic  Element, 
Douglas  County  Comprehensive  Plan.  Roseburg, 
Oreg. 

Downing,  Kent  and  Roger  N.  Clark 

1979.  Users'  and  Managers'  Perceptions  of 
Dispersed  Recreation  Impacts:  A  Focus  on  Roaded 
Forest  Lands.  In:  Recreational  Impact  on 
Wildlands:  Conference  Proceedings  October  27- 
29,  1978.  Seattle,  WA.  USDA,  Forest  Service;  USDI, 
National  Park  Service.  Pacific  Northwest  Region. 
33p. 

Edgerton,  Paul  J. 

1972.  Big  Game  Use  and  Habitat  Changes  in  a 
Recently  Logged  Mixed  Conifer  Forest  in 
Northeastern  Oregon.  Proc.  52nd  Annu.  Conf.  of 
West.  Assoc,  of  State  Fish  and  Game  Comm., 
Portland,  Oreg. 

and  Burt  R.  McConnell 

1976.  Diurnal  Temperature  Regimes  of  Logged 
and  Unlogged  mixed  Conifer  Stands  on  Elk 
Summer  Range.  USDA  Forest  Service  Research 
Note  PNW-277.  USDA  Forest  Service,  Portland, 
Oreg. 

Eligehausen,  H.,  J. A.  Guth,  and  H.O.  Esser. 

1980.  Factors  Determining  the  Bioaccumulation 
Potential  of  Pesticides  in  the  Individual 
Compartments  of  Aquatic  Food  Chains. 
Ecotoxicol.  Envir.  Safety.  4:134-157. 

Erman,  Don  C,  J.D.  Newbold  and  K.B.  Roby 

1977.  Evaluation  of  Streamside  Buffer  Strips  for 
Protecting  Aquatic  Organisms.  Contribution  No. 
165.  California  Water  Resources  Center.  University 
of  California,  Davis,  Calif. 


1978.  Projection  of  Future  Job  Losses  in  the 
Timber  Industry  in  Douglas  County  due  to  timber 
supply  declines  and  productivity  increases. 
Roseburg,  Oreg. 


199 


flacco,  Paul  Richard 

978.  Projected  Income  and  Employment  Impacts 
if  a  Decline  in  the  Timber  Resource  Base  of  a 
Highly  Timber-dependent  Economy.  M.S.  Thesis. 
)ept.  of  Agricultural  and  Resource  Economics, 
Dregon  State  University,  Corvallis,  Oreg. 

rranklin,  Jerry  F.  and  C.T.  Dyrness 

973.  Natural  Vegetation  of  Oregon  and 
Vashington.  USDA  For.  Serv.  Gen.  Tech.  Rep. 
'NW-8.  Pac.  Northwest  For.  and  Range  Exp.  Stn., 
'ortland,  Oreg. 

F.C.  Hall,  C.T.  Dyrness  and  C.  Maser 

972.  Federal  Research  Natural  Areas  in  Oregon 
ind  Washington  —  A  guidebook  for  Scientists  and 
Educators.  USDA,  Forest  Service,  Pac.  Northwest 
:or.  and  Range  Exp.  Stn.,  Portland,  Oreg. 

Kermit  Cromack,  Jr.,  William  Denison,  Arthur 
i/lcKee,  Chris  Maser,  James  Sedell,  Fred  Swanson 
ind  Glen  Juday 

1981.  Ecological  Characteristics  of  Old-Growth 
Douglas-fir  Forests  USDA  For.  Serv.  Gen.  Tech. 
3ep.  PNW-118,  48p.  Pac.  Northwest  For.  and 
3ange  Exp.  Stn.,  Portland,  Oreg. 

:ranzreb,  Kathleen  E.  and  Robert  D.  Ohmart 

I978.  The  Effects  of  Timber  Harvesting  on 
3reeding  Birds  in  a  Mixed  Coniferous  Forest, 
Condor  80:431-441. 

:redriksen,  R.L. 

1971.  Impact  of  Forest  Management  on  Stream 
A/ater  Quality  in  Western  Oregon.  In:  Pollution 
^atement  and  Control  in  the  Forest  Products 
ndustry,  1971-72  Proceedings,  USDA,  For.  Serv. 


1972.  Nutrient  Budget  of  a  Douglas-fir  Forest  on 
an  Experimental  Watershed  in  Western  Oregon. 
Symposium  proceedings  —  Research  on 
:oniferous  forest  ecosystem,  March  23-24. 

and  R.D.  Harr 


1979.  Soil,  Vegetation  and  Watershed  Management 
of  the  Douglas-Fir  Region.  In:  Forest  Soils  of  the 
Douglas-Fir  Region.  Northwest  Forest  Soils 
Council;  Washington  State  Cooperative  Extension 
Service,  Washington  State  University,  Pullman, 
Wash. 

Fritschen,  Bovee,  Beuttner,  Charlson,  Monteith, 
Pickford,  Murphy  and  Darley 

1970.  Slash  Fire  Atmospheric  Pollution.  USDA  For. 
Serv.  Res.  Pap.  PNW-97.  Pac.  Northwest  For.  and 
Range  Exp.  Stn.,  Portland,  Oreg. 

Froelich,  H. 

1982.  Personal  communication.  Soil  scientist, 
professor  Oregon  State  Univ.,  Corvallis,  Oreg. 


Gibbons,  D.R.  and  E.O.  Salo 

1973.  An  Annotated  Bibliography  of  the  Effects  of 
Logging  on  Fish  of  the  Western  U.S.  and  Canada. 
USDA  For.  Serv.  Gen.  Tech.  Rep.  PNW-10,  Pac. 
Northwest  For.  and  Range  Exp.  Stn.,  Portland, 
Oreg. 

Gratkowski,  H. 

1974.  Herbicidal  Drift  Control:  Aerial  Spray 
Equipment,  Formulations,  and  Supervision.  USDA 
For.  Serv.  Gen.  Tech.  Rep.  PNW-14.  Pac. 
Northwest  For.  and  Range  Exp.  Stn.,  Portland, 
Oreg. 

and  P.  Lauterback 

1974.  Releasing  Douglas-firs  from  Varnishleaf 
Ceanothus.  J.  For.  72(3):150. 

Grier,  Charles  C. 

1982.  Personal  communication.  Soil  scientist, 
professor,  University  of  Washington,  Seattle, 
Wash. 

and  Dale  W.  Cole 


1972.  Elemental  Transport  Changes  Occurring 
During  Development  of  a  Second-growth  Douglas- 
fir  Region.  Symposium  proceedings  —  Research 
on  coniferous  forest  ecosystems,  March  23-24. 

Hall,  Alfred  J. 

1972.  Forest  Fuels  Prescribed  Fire  and  Air  Quality. 
USDA,  For.  Service,  Pac.  Northwest  For.  and 
Range  Exp.  Stn.,  Portland,  Oreg. 

Hall,  James  D.,  and  Richard  Lantz 

1969.  Effects  of  Logging  on  the  Habitat  of  Coho 
Salmon  and  Cutthroat  Trout  in  Coastal  Streams. 
Cited  in:  The  Impact  of  Timber  Harvest  on  Soil  and 
Water  Resources,  George  W.  Brown.  Extension 
Bulletin  827,  Oregon  State  University  Extension 
Service,  Corvallis,  Oreg. 

Harper,  James  A. 

1969.  Relations  of  Elk  to  Reforestation  in  the 
Pacific  Northwest.  In:  Wildlife  and  Reforestation  in 
the  Pacific  Northwest.  Proc.  of  a  Symposium  held 
September  12-13,  1968,  pp.' 67-71.  Oregon  State 
University,  Corvallis,  Oreg. 

Harris,  D.  D. 

1977.  Hydrologic  Changes  after  Logging  in  Two 
Small  Oregon  Coastal  Watersheds.  U.S. 
Geological  Survey  Water  Supply  Paper  2037. 

Hartung,  R. 

1965.  Effects  of  Oiling  on  Reproduction  of  Ducks. 
J.  Wildl.  Mgmt.  29(5):  pp.  872-874. 


1966.  Toxicity  of  Some  Oils  to  Waterfowl.  J.  Wildl. 
Mgmt.  30(3):  pp.  564-570. 

Hassleman,  R. 

1979.  Personal  communication.  Fisheries  Planner 
and  Fish  Division  Budget  Coordinator.  Oregon 
Dept.  of  Fish  and  Wildlife.  Portland,  Oreg. 


200 

Haynes,  Richard  W. 

1977.  A  Derived  Demand  Approach  to  Estimating 
the  Linkage  Between  Stumpage  and  Lumber 
Markets.  Forest  Science  Vol.  23,  No.  2,  June  1977. 

and  Darius  M.  Adams 

1979.  Impacts  of  RARE  II  Withdrawals  on 
Softwood  Prices,  Consumption,  and  Production. 
Journal  of  Forestry,  Vol.  78,  No.  4,  April  1979. 

Kent  P.  Connaughton,  and  Darius  M.  Adams 

1980.  Stumpage  Price  Projections  for  Selected 
Western  Species.  Research  Note  PNW-367,  Pac. 
Northwest  For.  and  Range  Exp.  Stn.,  USDA,  For. 
Serv.,  Portland,  Oreg. 


1981.  Projections  of  the  Demand  for  National 
Forest  Stumpage  by  Region;  1980-2030.  Research 
Paper  PNW-282,  Pac.  Northwest  For.  and  Range 
Exp.  Stn.,  USDA,  For.  Serv.,  Portland,  Oreg. 

Heilman,  Paul  E. 

1981 .  In:  Forest  Soils  of  the  Douglas-fir  Region. 
Edited  by:  Paul  E.  Heilman,  Harry  W.  Anderson, 
David  M.  Baumgartner.  Washington  State 
University. 

Honey,  William  and  Thomas  C.  Hogg 

1980.  Cultural  Resource  Overview:  Umpqua 
National  Forest  and  Bureau  of  Land  Management, 
Roseburg  District.  Oregon  State  University,  Dept. 
of  Anthropology,  Corvallis,  Oreg. 

Hoyer,  G.E. 

1975.  Measuring  and  Interpreting  Douglas-Fir 
Management  Practices.  DfMR  Report  No.  26, 
Washington  Department  of  Natural  Resources, 
Olympia,  Wash. 

Hughes,  Dallas  R.  and  Rudolph  V.  Edwards,  Jr. 

1978.  Granite  Creek  landslip  survey.  Umpqua 
National  Forest.  PNW  Region,  USDA,  Roseburg, 
Oreg. 

Jenkins,  Kurt  and  Edward  Starkey 

1980.  Rosevelt  Elk  of  the  Hoh  Valley,  Olympic 
National  Park.  Oregon  Cooperative  Park  Studies 
Unit,  Report  80-3,  School  of  Forestry,  Oregon 
State  University,  Corvallis,  Oreg. 

Jensen,  Harold 

1979.  Personal  communication.  Douglas  County 
Budget  Director,  Roseburg,  Oreg. 

Ketcheson,  Gary  and  Henry  A.  Froehlich 

1978.  Hydrologic  Factors  and  Environmental 
Impacts  of  Mass  Movements  in  the  Oregon  Coast 
Range.  Water  Resources  Research  Institute, 
Oregon  State  University,  Corvallis,  Oreg. 


Kovner,  J.L. 

1956.  Evapotranspiration  and  Water  Yields 
Following  Forest  Cutting  and  Natural  Regrowth. 
Soc.  Am.  Foresters  Proa,  p.  106-110.  In:  R.  Dennis 
Harr,  Richard  L.  Fredriksen  and  Jack  Rothacher. 

1979.  Changes  in  Streamflow  Following  Harvest  in 
Southwestern  Oregon.  Research  Paper  PNW-249, 
Pac.  Northwest  For.  and  Range  Exp.  Stn.,  USDA, 
Forest  Service,  Portland,  Oreg. 

Lang,  F.J. 

1980.  Old-growth  Forests  of  the  Douglas-fir 
Region  of  Western  Oregon  and  Western 
Washington:  Characteristics  and  management. 
Jones  and  Stokes  Associates,  Inc.,  Sacramento, 
Calif.  61p. 

Lavy,  T.L.,  J.D.  Walstad,  R.R.  Flynn,  and  J.D. 
Mattice. 

1982.  2,4-D  Exposure  Received  by  Aerial 
Application  Crews  during  Forest  Spray 
Operations.  Journ.  Agric.  Food  Chem.  30:375-381. 

Leng,  M.L.,  J.C.  Ramsey,  W.H.  Braun,  and  T.L. 
Lavy. 

1982.     Review    of    Studies    with     2,4,5- 
trichlorophenoxyacetic  Acid  in  Humans  including 
Applicators  under  Field  Conditions.  Amer.  Chem. 
Soc.  Symp.  Ser:182. 

Levno,  Al  and  Jack  Rothacher 

1969.  Increases  in  Maximum  Stream  Temperatures 
after  Slash  Burning  in  a  Small  Experimental 
Watershed.  USDA,  For.  Serv.  Res.  Note  PNW-110. 
Pac.  Northwest  For.  and  Range  Exp.  Stn., 
Portland,  Oreg. 

Lilly,  John 

1981.  Personal  communication.  Oregon 
Department  of  Transportation,  Parks  and 
Recreation  Branch,  Salem,  Oreg. 

Lyon,  L.  Jack 

1979.  Habitat  Effectiveness  for  Elk  as  Influenced 
by  Roads  and  Cover.  Journ